When an existing customer closes all accounts, and there is no active relationship, is there a stipulation that if the "old" customer returns to the FI and opens a new account within 12 months of all other accounts being closed, there is no requirement for CIP?
We have opened an "non-traditional" banking facility that serves the Latino community. We are requiring that the new customer provide us with either a SSN or ITIN or attest that they have applied for same when opening a non-interest bearing account. I have been met with some resistance. Where can I find the requirement other than our Know Your Customer Policy, Money Laundering Policy and BSA Policy that makes this a federal requirement that banks absolutely must have Tax ID numbers on all accounts?