I searched for an answer to the following question but I still have doubts.
Is there a Reg B problem for keeping Identifications on Denial Files? If the applicant is a new customer the lender would ask for IDs. How do we document this is not a discriminatory procedure but a CIP for BSA purposes.

Why would you be gathering CIP information prior to agreeing to make them a customer?

It seems some one told a lender to start getting IDs at application some time last year so they would not miss the CIP requirement.