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Recordkeeping of CIP Information

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Question: 
What CIP information needs to be kept for recordkeeping purposes?
Answer: 

The requirement is spelled out in the CIP regulations, 31 CFR 103.121(b)(3)(ii). You need to separate your CIP information on a customer into two groups.

The first group includes the four elements of identification information: name, street address, date of birth (for individuals), and identification number. This information must be retained until five years after the account is closed (for credit card accounts, five years after the account is closed or becomes dormant).

The second group includes a description of any documents used to verify the customer's identity, description of methods used in and results from any non-documentary verification attempts to verify the customer's identity, and additional information obtained to verify the identity of individuals controlling an account of an entity, when unable to verify the identity of the entity itself. This group of information is to be retained for five years from when it was collected.

First published on BankersOnline.com 7/26/09

First published on 07/26/2009

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