Are we required to collect CIP information on customers who are grandfathered that come in to open a new account? An employee at the bank thinks that if we get the opportunity we should request/obtain updated CIP information on customers who are grandfathered. I'm wondering if this is required or even necessary. Any feedback is appreciated.

Any special treatment given to existing customers is a function of your CIP, not the regulation. Whether it is a good idea to obtain missing information on those customers is a decision your bank made 5 years ago.

I personally think that it is a good idea to update records to obtain significant information such as a missing TIN, DOB or ID. The primary purpose is not necessarily to determine the identity of the customer, but rather to have info we may need for other purposes, such as filing CTRs, MIL records. Having basic identifying information on file can streamline service and documentation procedures (especially in an automated environment).

That being said, we identified potential CIP issues through the process. When pressed for ID of individuals depositing payroll checks for years, we were given bogus SSNs in a number of situations. That definitely made me question whether we had accurately identified those individuals at account opening. Could other information provided by these persons, including names, be fictitious as well?

While employed at another FI, a new Teller asked for an existing customer's ID. When presented, the DOB did not match our records. As it turned out, our customer was actually the grandmother of the person attempting to withdraw funds from the account. The granddaughter (grandmother's namesake) was ripping our customer off. Had we not had the DOB on file, the granddaughter may have gotten away with identity theft.

Several of our Tellers were familiar with grandmom, but not the new Teller. And, certainly, no one was familiar with the granddaughter.