Our internal security/BSA officer asked if we have any procedures on what we do if a person opens a new account and presents a drivers license that's about to expire. We don't have anything in our procedures to address this. As far as I'm concerned if the license is unexpired when they open the account, no additional steps should be required. Apparently we've had a few customers recently with this exact scenario--I think one had a license that was expiring the very next day. We enter the license # and expiration date in their customer profile and every month she pulls a report to see what CIP information might be missing from new accounts that are opened. I can't imagine telling customers that they have to come back in when their license expires so we can update our system. Thoughts?

You're correct, no further action is necessary. It is a valid form of ID when accepted, you're good to go.

Agreed; if it's valid as of the day you open the account, it's valid!

The purpose of CIP is to form a reasonable belief that you know the true identity of each customer. The customer does not suddenly have a different identity the day after their license expires.