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#637706 - 11/13/06 09:12 PM CIP Record Retention
Happy Apple Offline
Junior Member
Joined: Oct 2006
Posts: 39
South Dakota
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).

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#637707 - 11/13/06 09:26 PM Re: CIP Record Retention
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,911
Galveston, TX
Whether or not you need to contact these customers to mitigate the risk of being cited for a violation will be up to the bank to determine.

However, "the others" are correct. If your CIP procedures indicate that you are relying on documents to verify identity, then all of the listed items (if applicable) must be maintained. For example, in many states, the DL has no issuance date, only an expiration date so in those cases you would not have a issuance date.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#662174 - 01/05/07 09:59 PM Re: CIP Record Retention rlcarey
SARempress Offline
Junior Member
Joined: Jul 2006
Posts: 37
Deep in the Heart of Texas
I have a question regarding the "place of issuance" for passports. We have been documenting the "country of issuance" in our CIF along with the numbers and dates of issuance/expiration, which as I understand it, covers us for those foreigners who do not have a TIN. During a recent review, our auditor said we need to record both the "country" and the "place" of issuance for passports. His theory is that there is a difference between a US passport issued in Texas as opposed to a US passport issued by a consulate office outside the states. I have not heard this before and frankly do not agree with him. Is anyone else recording both? What is correct?

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#662191 - 01/05/07 10:14 PM Re: CIP Record Retention SARempress
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,911
Galveston, TX
The regulation states:

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.

Unless your CIP policy and procedures calls for documenting the "place of issuance" I would ask your auditor where they came up with this idea.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#662202 - 01/05/07 10:20 PM Re: CIP Record Retention rlcarey
SARempress Offline
Junior Member
Joined: Jul 2006
Posts: 37
Deep in the Heart of Texas
I think he's pulling that from the record retention piece where it states to record a description of any document used to verify the customer's identity; this section actually states "place of issuance." Generally, we use the customer's foreign passport as both their primary ID and to sub for the TIN.

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