Answer:
If they are an existing customer, CIP does not apply to them provided you have a reasonable belief that you know the true identity of the customer. Refer to Section 103.121(A)(3)(ii)(C).
First published on BankersOnline.com 2/16/09
Old Customer, New Signature Card. CIP Required?
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Question:
We have a customer who was with us before all the CIP requirements, and they are doing something to their accounts that requires a new signature card. Do we have to get updated CIP information? I know it’s good practice and I already advised it, but I was wondering if there was a compliance requirement to get the information in this case.
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