It has always been my understanding that when the bank's CIP is written it includes the list of acceptable primary and secondary identification and the policy is approved by the board of directors. Any changes to the policy, including additions or deletions to the list of acceptable primary and secondary identification, must be approved by the board. Do I have this correct? If I'm off track can you please set me straight?

The "primary" and "secondary" concepts regarding identification are not expressed in the regulation or the supplementary information that accompanied it. They fall under the heading of "best practices."

However, the ideas that your CIP must include a list of what you regard as acceptable identification and that it must be approved by and revised by the Board reflect the gospel.

Thank you, Ken.

P.S. I got a good chuckle from your signature phrase.