Ihave read so much on this issue an now I am totally confused.We capture the basic ID information from the consumer. Then we verify it using documentary or non-documentary methods. Is the basic information (name, address, DOB and SS#) what has to be retained for 5 years after the accounts closes, or the documents used to verify the id of the consumer?

Especially look at Ted's comments.

If you read the retention of records section of the regulation, it states:

(ii)Retention of records. The bank must retain the information in paragraph (b)(3)(i)(A) [that is the basic identifying information - name, address, dob, ssn] of this section for five years after the date the account is closed or, in the case of credit card accounts, five years after the account is closed or becomes dormant. The bank must retain the information in paragraphs (b)(3)(i)(B), (C), and (D) of this section [that is a description of any document relied on to verify identity, a description of any non-documentary method used and its results, and a description of the resoultion of any substantive discrepancy discovered] for five years after the record is made.