Craney, I'm not aware of any regulation that addresses this because as Rlcarey said, in theory you shouldn't be opening accounts without proper CIP. However, in practice, it's impossible, no institution on this planet has 100% compliance. So BSA programs typically monitor for CIP related issues and build in a remedy period to resolve CIP issues that are identified. My bank's program is 30 days. Mistakes happen, policy addresses it and gives a remediation period.