we do our customer due diligence via a questionnaire where we inquire as to the nature of the business and the expected cash activity on the account.
The question has come up, what if the customer comes in and opens up a 2nd DDA.
Should we have him/her go through the same questionnaire on the second account or do we have it covered via the questionnaire we filled out on the initial account?

There is no right or wrong answer, so I'll answer a question with a question.

Will my operating account, lottery account, payroll account, and ATM account have the same anticipated activity and will your initial questionnaire provide you with enough information to understand the normal and expected activity for my total relationship or will the opening of this second account require some additional due diligence on your part?

Since you will be obtaining updated beneficial ownership information on my business each time I open a new account as of 5/11/18, it may help to have your retail staff ready for that change by obtaining anticipated activity for each business account now.

Brian's advice makes sense. Soon we will need to obtain BOI and it applies to each account, so it makes sense to collect profile information at the same time.'

When I did BSA, my CIP form was separate from my profile forms that collected information regarding expected activity. At this time, CIP is a one time event. However, you need to understand the expected activity for EACH account, as they may be different as Brian explained.

Once BO comes into play, we will have to make some changes.

To streamline this process, we've classified onboarding information into two (2) categories, customer specific and account specific. Customer specific information doesn't usually change across accounts. The customer is still an LLC, authorized these signors, is located at this address, etc. Account specific information always needs to be asked (Purpose of the account, source of funds, BO's, etc.).

This took a long time to implement, as front end staff still need to ask questions to verify that no changes have occurred with customer specific information. Typically BO's will inquire if there have been any changes since your last account, will the signors be the same, etc. We've seen significant time savings with account opening, it just took a while to get there.