Answer:
The CIP regulations allow you to skip the ID gathering and verification steps if the loan applicant is an existing customer of your bank, and the bank is satisfied that it knows the customer's true identity. If your bank's CIP policy allows you to take advantage of that provision of the regulation, the customer's account is currently open, and you are satisfied that you know the customer's true identity, you may treat the applicant as an existing customer and skip the CIP requirement.
First published on BankersOnline.com 7/17/06