In this case, the CIP must include procedures to confirm that the application was filed before the customer opens the account and to obtain the taxpayer identification number within a reasonable period of time after the account is opened.
Your procedures must require you to obtain the TIN, nothing less. If you don't get it the account should be closed.
The CIP regulation dances around the idea of controlling the customer's use of the account in circumstances where the bank is unable to verify identity. However, it does not suggest the same response is possible when the bank fails to obtain one of the four required pieces of information.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.