CIP Disclosure - Can It Be Combined?

Currently I have a standalone CIP Disclosure Notice which all applicants for a new account and the employee opening the account sign. I do not require them to give the applicant(s) a copy to keep.

Management wants to combine this form with the New Account Set-up Sheets for Individuals AND Businesses (into one legal length form). This is to save paper, which is a valid goal to have.

Must this disclosure be standalone and in a form the customer may keep, or is it sufficient to have them read and sign the notice, then have the employee gather the CIP information, but not provide the applicant(s) with a copy of the combined form?

Please help!

There is nothing in Section 326 that says that the disclosure notice has to be in printed form for the customer/borrower. In fact, you can simply post the disclosure in a conspicuous place or have desk signs made for each desk. You can even read it aloud to the borrower if you have a telephone application. The notice does not have to be signed. You just have to be able to prove that the borrower saw/received it.

Here's where renniks gets his or her material:

(5)(i) Customer notice. The CIP must include procedures for providing bank customers with adequate notice that the bank is requesting information to verify their identities.

(ii) Adequate notice. Notice is adequate if the bank generally describes the identification requirements of this section and provides the notice in a manner reasonably designed to ensure that a customer is able to view the notice, or is otherwise given notice, before opening an account. For example, depending upon the manner in which the account is opened, a bank may post a notice in the lobby or on its website, include thenotice on its account applications, or use any other form of written or oral notice.

Your procedures make this harder than it has to be. I encourage you to get rid of the requirement that the customer acknowledge receipt. It cannot help you, but if reviewers find files where there is no acknowledgement, it can definitely hurt you. Review your board approved CIP to see what you required there. Amend it if necessary.

Thanks everybody! I was only 6 months on the job when CIP went into efferct, and it was my first policy. I am doing a rewrite now and will likely back off on a few things. Now that I am a "seasoned veteran" Compliance Officer (two years, ha), I am learning to be a little less conservative.