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#109115 - 08/21/03 10:26 PM CIP Checklist
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
I'm trying to find a checklist to use when reviewing the bank's written Customer Identification Program to make sure we don't miss any of the required elements of the program. I must be looking in all the wrong places, because I can't find one.

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BSA/AML/CIP/OFAC Forum
#109116 - 08/22/03 01:42 AM Re: CIP Checklist
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Exam guidance isn't put together yet and I don't know of any banks who have done this on their own. It wouldn't be difficult to go through the reg and denote the regulatory requirements. The tough part will be the subjectivity of what is risk based and acceptable.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#109117 - 08/22/03 05:42 AM Re: CIP Checklist
wavewatcher Offline
Diamond Poster
wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
Our FDIC examiner used some sort of checklist (I presume) because he told me that our CIP had all the components off his checklist. I asked to see the checklist, and he politely informed me that it wasn't public.

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#109118 - 08/22/03 01:14 PM Re: CIP Checklist
Rubaiyat Offline
Diamond Poster
Joined: Jun 2001
Posts: 1,373
Lido Deck
I have a sample audit worksheet that I found somewhere when I was researching CIP, but I don't remember where I got it. It is a hard copy that I could fax to you if you PM me with your fax number. It is very comprehensive and is what I used to make sure our CIP had all the required elements.
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#109119 - 08/22/03 01:27 PM Re: CIP Checklist
downstown Offline
Gold Star
Joined: Aug 2001
Posts: 295
St. Louis, MO
CEO Memo # 175 from the OTS contains a checklist that may be helpful.

Also, I have a checklist that I got from Kirchman. If you can't find it on their website PM me and I will forward a copy to you.

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#109120 - 08/27/03 07:01 PM Re: CIP Checklist
downstown Offline
Gold Star
Joined: Aug 2001
Posts: 295
St. Louis, MO
Mary Beth and Ken have prepared a checklist. It is in the AML Center.

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