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#1451752 - 10/05/10 04:00 PM BSA/Lending Compliance
dac Offline
100 Club
Joined: Sep 2009
Posts: 234
We were told by our auditor that we must get a copy of valid Photo ID every time we extend new credit if the ID we have on file is expired. The customer has a history with the bank and CIP/BSA was done when they became a bank customer. Is this a Regulation or best practice?

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Lending Compliance
#1451775 - 10/05/10 04:15 PM Re: BSA/Lending Compliance dac
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Honestly, I don't think it's either. Ask your auditor for the citation to go along with this request.
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#1451777 - 10/05/10 04:16 PM Re: BSA/Lending Compliance dac
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Existing customers are exempt from CIP. Tell your auditor to read the reg first. If the customer has an EXISTING loan, then are exempt. If they had a previous loan (now paid off), they are not exempt and you must re-CIP them.
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David Dickinson
http://www.bankerscompliance.com

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