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I'm Cleaning up our CIP Files

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Question: 
I've recently started with a community bank, and began the process of cleaning up our Customer Identification Files. For closed accounts that have incorrect or missing information as required by the Patriot Act, are we required to go back and correct those? If so, how far back do we have to go? If we are unable to obtain the correct information on the closed account, will that become a finding from the auditors?
Answer: 

This is a very difficult position to be in (especially as a new employee). However, you may want to use this regulatory issue as an opportunity to build a BSA/AML committee within your bank. This committee should consist of senior level management who can review the severity of the situation and make a risk-based decision for the bank. Ideally, this committee will help you develop a plan that can be shared with your auditors when they ask how you are addressing the problem.

First published on BankersOnline.com 3/6/06

First published on 03/06/2006

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