Ok we were just asked to incorporate a Customer Due Diligence program into our CIP procedures. What I don't get about CDD is that it seems like they want a risk profile of every customer of the institution. How are we expected to review every customer file, or do they just mean one's that are being opened or re-opened.

how many customers (not account) do you estimate you have? we did a risk profile sheet for all existing customers back in March, which was about 1800 customers. and we use the same sort of sheet for all new customers (but not existing customers who open new accounts).

We have Personal Banker's (New Acct. Reps.) who do it but they have absolutely no time for. Actually no one has time to do it manually. What in the world am I supposed to do???

When we implimented CDD into our CIP program we have a date established when it would start so that we didn't have to go through the whole data base. As existing customers open new accounts, we get the information and update their profiles. So far, that seems to be acceptable.

Thank you. I did'nt want to get over-complicated on this and as far as manually doing it.... We have a BSA automated system but it doesn't sweep our accounts for high risk rated activity in a way that finds high risk customers for us.