Several of us here are having a difference of opinion on what the reg actually is saying in regards to CIP record retention.
Specifically this statement: The bank must also keep a description of the following for five years after the record was made: Any document that was relied on to verify identity, noting the type of document, the identification number, the place of issuance, and, if any, the date of issuance and expiration date.
Up until about a year ago, the bank's CIP did not require obtaining an issuance date from the identifying information (e.g.: driver's license) so we do not have a lot of issuance dates. We documented everything else from the ID except the issuance date. I say, that up until the policy and procedure was changed, we didn't collect it, didn't use it to identify, therefore we don't need to retain it. The others here are saying we need to contact the customers (100's of them), collect the issuance date of their ID, and record it because the above statement includes "date of issuance" and for us not to collect the issuance date is a violation of regs and an oversight on the bank's part.
Am I the one being thick-headed here? Please help. Any supporting documentation would be appreciated (either way).