Customer opens an account and we CIP them. The customer moves and closes their account. The customer comes back a year later and now since they are a new "customer" we CIP them again. Can we purge the "old" CIP info, or do we have keep this since the retention is 5 years after the account closes. Currently, with our filing system, we CIP them, then never remove the CIP file.... Since this is our filing system, we in this case have 2 CIP files. Can we purge the old one and replace it with the new CIP info?

No. Each CIP record stands on its own, and has to be retained until five years after the customer's account(s) are closed. So you will have two CIP records for that customer until five years after the first account closed.

Thank you.