Skip to content
 

Are Former Customers Considered "New" Customers?

Answered by: 
Ken Golliher

Question: 
How does the new Patriot Act regarding CIP address closed accounts? What I mean is if a customer has closed an account but still is on our operating system with all information, are they considered a new customer if they come in to open a new account?
Answer: 

The regulation creates a possible distinction for customers with "existing" accounts. It's pretty objective, they either have a formal banking relationship with you at the time the new account is opened or they do not.

First published on BankersOnline.com 8/25/03

First published on 08/25/2003

Filed under: 
Compliance
Filed under compliance as: 
CIP

Report a problem with this page

Search Topics