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Deadline for Customer Due Diligence & Risk Rating

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I understand the Deadline for CIP was October . Is there a deadline for Customer Due Diligence and Risk Rating? Are the auditors checking for this now?

CIP requirements are a function of a regulation that took effect October 1, 2003. Customer due diligence and enhanced customer due diligence which may result in a risk rating do not reflect a regulatory requirement per se. Instead, they reflect concepts set out in examination procedures published in June of 2005.

In effect, your institution can expect to have these standards applied in its next on-site examination. Obviously, some institutions have more time to prepare than others. To date, my anecdotal experience is that regulators are taking that into account. Their general expectation is that banks are familiar with the new terms and their implications and that they are making progress toward revising their programs accordingly. There is no widespread expectation that every bank will have completely revised its program by their first on-site examination after the revised procedures were published.

First published on 5/1/06

First published on 05/01/2006

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