BSA/CIP

If there is an address discrepancy in a loan file (drivers license has a different address from the subject property which is owner occupied) and the lender documents occupancy sufficiently through a letter of explanations, Fraud Guard, or other documentary items, is it required for the lender to also include a summary of how the issue was cleared if the documentation speaks for itself? Can anyone reference a regulation requiring, or not requiring this extra step?

31 CFR 1020.200(a):

(3) Recordkeeping. The CIP must include procedures for making and maintaining a record of all information obtained under the procedures implementing paragraph (a) of this section.

(i) Required records. At a minimum, the record must include:

(D) A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.

Whatever you feel meets this requirement is what you keep in the file.