Thank you for giving me the chance to post and remain anonymous.
I work at a bank and someone new has been asked to look at regulations and give feedback on an issue. I was hoping to ask you all and if they are correct or incorrect so I could help point them in the right direction.
The question is about CDD and CIP with existing customers. Executives are asking about what we have to do for CDD if we have a triggering activity with an individual. Our policy says if an existing customer opens a new checking or savings we will update their information and a new CD we would not.
The person indicated that this is not a regulation point and more likely just what we decided our risk appetite is. CDD was introduced to encompass legal entities and we can still use CIP for our existing customer. They are both (CDD CIP) kinda married to each other at this point.
There is a bit I am leaving out as I was not really in the deep end of the conversation but I hope you all see what I am asking. Is the bank supposed to perform CIP/CDD if an existing customer does something not related to legal entities?
I know we have to complete what our policies say. I don't know if CDD triggering activities effect individuals when they open a new checking account say. I will read tonight the regulations the person sent me so I can learn more about it. It is hard to find a direct answer online but I will up my game on reading regs and guidance.
Does anyone have thoughts? I'm sorry for my lack of understanding of the topic but I do not want this person to go in alone as a new person
Any help would be appreciated. I will check back in often.
Thanks a bunch.