Thread Starter: TryingtoComply
Title: Re: CIP exceptions
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The language Brian cited pertains to the pieces of information that must be collected for CIP (name, DOB, TIN, ID). Is your question related to missing documentation at account opening?
We have a CIP Exception form and the BSA Officer or Asst BSA Officer must approve all exceptions, which are typically related to a missing document that is usually obtained within 30 days. We have one or two insignificant exceptions per year. You need to be able to track them as auditors and examiners will ask if there have been any exceptions. You don't want them to find them during transaction testing without you already knowing about them.
When we do our annual and new hire training, we emphasize that our CIP procedure is board approved and that no manager, etc. has authority to approve an exception. I included a quiz question on it when I created our custom online training course to emphasize this point.
We spell it out in our procedures as well.
The annual online training is a continual reminder.
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