I know we're required to retain the CIP info obtained at account opening. However I've recently run across something in our system that concerns me and am hoping for some ideas on how other banks are managing this.

Currently, we input all CIP info into our core system. The system, prior to purging customer records, saves the data in these fields to a database where it sits for the required retention period.

Here's the problem. If a customer moves or changes their name while their account is with us, the fields for name and address are updated thereby wiping out the initial information.

I've got a couple alternate ideas on how we could handle this, but none of them are particularly pleasant from a process standpoint. Anyone have any thoughts they'd be willing to share?

You already know that the original information should not be changed unless it was recorded incorrectly. Are the changes being made by some well-meaning clerk who doesn't know any better, or are they automatically updated with changed information (bad system design)?

John - Really it's a system issue. The problem is that when things about the customer change, the system is updated with current info. There are no separate fields for CIP original info that protect it when customers move and change their address...or get married and change their name.

Back when they were first trying to figure all this out, the thought was to use sig cards as the record. Unfortunately, cards have a way of getting misplaced too often for me to feel good about that solution.

Does your bank use a document imaging system? Frankly, the CIP retention rule (5 years beyond account closure) is overly burdensome. With system changes and upgrades, it's hard to be certain that even imaged documents will be retrievable for that long. And we all know how wonderful paper-based filing systems are.

It's a conundrum, for certain.

Our CIF system tracks all maintenance changes. You can see what the original address was even though it had been changed at some point. I would think that most systems in today's environment would have the same capability. If you are purging prior to 5 years after account closes, maybe you should look into 'saving' the maintenance files to disc to satisfy this retention.

Thanks everyone for your input.

We've decided to move the CIP info for individuals onto the signature card so that it can be scanned. It was moved onto its own form several years ago and I have no clue why they did it. That solves the bulk of my problem since address changes on businesses don't occur very often.

GP - One would think that our system would be able to do what you describe. However, the one thing I've learned about our core system is that it never does what we think it should!