If the bank obtains the name, address and TIN of a CD owner at inception - does it have to obtain the information again when that owner redeems the CD under 31CFR103.34(b)?

Also, is there any regulatory reason(s) to obtain identification from the owner redeeming the CD? I certainly see a need from an identity theft or fraud perspective. Specifically, I am trying to determine a compliant procedure for when CD owners mail in the CD at maturity and ask for a check to be mailed to them.

Thanks

It's my understanding that there are no requirements to re-check anyone that currently has an account and, therefore, transactions on those accounts as far as ID is concerned, unless you feel that the ID of that person is now in question.

Prior to finalization, the "Act" included checking each time a customer opened a new account, but that provision was eliminated.

BKB, I would also consider the following when closing a CD via the mail (or any account, for that matter):
1. Verify the signature.
2. Verify the mailing address.
3. If either is out of sync with your records, I would go further, such as calling the customer to verify their identity (ask some personal questions).
If I still felt uncomfortable, I would asked for a notarized withdrawal slip and waive the penalty if time is an issue.
Hope this helps.

Let's not confuse the issue. 103.34(b)(12) is still in effect and has nothing to do with CIP. If I remember correctly, the purpose for obtaining ID at the sale of a CD and again at the redemption of a CD goes back to the practice of issuing bearer CDs. IRS wanted to know who bought them and who redeemed them, just in case the the parties were different.