Good Morning,

QUESTION IS: Does the below fall into the category of MODIFIED or EXPANDED services relative to OCC Guidance: OCC Bulletin 2017-43?
We are currently very strict on what ID we accept for CIP purposes on Non Resident Aliens - they must have a valid Passport, unexpired/current I-94 and Visa. HOWEVER -due to the border changes, we are going to change policy to accept Passport or Employment Authorization card along with secondary ID - to verify CIP. They will also be required to provide an ITIN or SSN if working.

Since this will increase our market for Non Resident Alien customers (therefore an expansion of services to NRA individuals) - does this CIP policy change require approval of our New Product and Services Committee in your opinion? Serious debate going on here and need some assistance with clarification.

One side - additional NRA customers will be able to bank with us = expanded service.
Other side - this is not a service or product, it is simply a CIP change in policy.

Thanks!

I am in the camp that a revision to your Board approved CIP isn't a new product.

Thanks - that is my take as well.