Will we have to have two separate policies that say essentially the same thing, or will the "Know Your Customer" policy/procedures just be updated to agree with the CIP guidelines?

This stuff is getting so time consuming.

I recommend simply updating your existing KYC program/policy to comply with the CIP requirements. If you do it now, however, you run the risk of having to do it a second time, since there may be changes when the rules are actually finalized.

We are updating our KYC policy as well. However, we are prepared to present our revised policy to the board as soon as they finalize the rule. If they do make changes it will take less time to make minor modifications rather than to begin at that time so as to be sure to have it in place by the effective date.

We have a "Know Your Customer" policy statement and a "Know Your Customer" procedure.

The KYC statement speaks to the issues of identifying what is normal for a customer, what may constitute suspicious activity, things of that nature. It statement follows a lot of the recommendations contained in the OCC guidance on money laundering.

The KYC procedure, which will probably be renamed the CIP, speaks to the specific pieces of identification that are required and acceptable for individual and business accounts.

I'm still trying to think how we will maintain all those copies of Drivers Licenses!