I'm looking for assistance regarding CIP identification collecting and retention. We would like to streamline our current policy:


Do you have a form to record identification or do you record it electronically? If you have a form would you be willing to share?

When do you collect identification? Does it have to be collected before an account can be opened? Can a deposit account be opened without identification and have identification presented later?

Do you require identification on existing accounts?

Do you maintain a copy of the identification presented?

Do you require identification and personal information from Authorized Signers on business accounts (such as a Corporation)?

Any assistance is appreciated!

Do you have a form to record identification or do you record it electronically? If you have a form would you be willing to share?

At my former bank, it was collected electronically and input into our system at account opening. On commercial loans, however, it was collected on a form and input when the loan was booked.

When do you collect identification? Does it have to be collected before an account can be opened? Can a deposit account be opened without identification and have identification presented later?

It is possible, but it depends on your bank's policy. The requirements are to collect the information and verify it. Verification can be performed after the fact, but I would not advise waiting to collect the verification unless you can block transactions until the verifications are performed.

Do you require identification on existing accounts?

We left that up to the individual. If, for example, I was a new CSR and did not know someone, I might ask for identification, because my rear end is on the line. We encouraged our staff to collect any missing identification, such as missing SSN or DOB, if possible.

Do you maintain a copy of the identification presented?

Not for consumer deposit accounts, but we did require that all information be recorded, such as they type of ID, the issuing entity, issue and expirations dates, and number. However, for commercial accounts or any kind of loan account, the documentation relied upon was retained, such as articles of incorporation, paystubs, tax returns, W2s, etc. We did not retain copies of driver's licenses in the loan file to prevent any appearance of impropriety, particuarly if the loan went to collection.

Do you require identification and personal information from Authorized Signers on business accounts (such as a Corporation)?

Generally, yes, because it was out bank's policy prior to CIP and it was just easier to retain what everyone was used to. However, your bank's policy could depend on the type of business. The regs do not require it, except for high-risk entities.

We get a government issued photo ID for everyone who signs on an account, consumer or commercial and these IDs are imaged and the ID type and number are entered into our mainframe at the customer level. We also collect their DOB, address and SS#.

We do not open an account until we have the photo ID for everyone because our policy states this. Your policy should specify what type of ID and when you will collect it.

If an existing customer comes in to open an account, we have the personal banker check for existing ID and if it is on file and legible (such as can you make out the photo and the numbers) then we do not require them to get new ID. CIP states you only have to ID the customer when establishing your initial account.

Hope this helps.

What if the customer does not have social security number and will not give home address. I just took this job and found an account like this - we have out of country photo DL and that's it! Where can I quickly find reference for this situation? I have examiners here and one very upset bank officer. HELP!

Maybe I am over reacting, but if a customer told me that they refuse to supply a home address, I would close out the account.

I agree with ACB, I would close the account. We have too many documents (CTRs, SARs, etc) that require that we list the customer's physical address and social security number.

That's what I'm trying to do (quickly). I've not had this situation before. This customer states he has an account with another FI and they did not require SSN or tax number and he used his work address there too. We have nothing on this man except an out of country photo DL. I have found under CIP that we can use a different identifying number but I'm not comfortable with that and know nothing about those kinds of alternatives. Can you help me find something to reference? I am really lost on this.

You will find the requirements here:

http://www.bankersonline.com/aml/326finalrule.pdf

According to the Final Regs for CIP, a bank must obtain:
Name
Address (physical street address)
SSN or EIN
DOB (for individuals)

If the customer refuses to provide any of these pieces of information, and the account was established after implementation of 326, the account should be closed. Your customer may be correct that he was not asked to provide this information pior to CIP, but things have changed!

As far as verification of the information is concerned, for a non-US person, if your bank's policy is to rely on documentary ID, you need to obtain a photo ID with an identifying number, such as a passport, or other government-issued ID. If your bank does not rely on documents and performs only non-documentary identifications, you need to be able to form a "reasonable belief" that you know the true identity of this customer, using whatever means you have established through your CIP policy.

Thank you so very much for this link. It is exactly what I need and I am going into meeting now to take care of this problem. Again, thank you.

FYI. 31 C.F.R. 103.121 (b)(2)(i)(A)(4)(ii) non-U.S. person (individual) is not required to have SSN or EIN.

(ii) For a non-U.S. person, one or more of the following: a taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

How large of a hole is this. I can't see this as protective to the USA.