CIP Record Retention - Mary Beth Guard

CIP Record Retention
by Mary Beth Guard, BOL Guru

Question: In the record retention requirement for the CIP, does it require that we have the actual input sheet, or if the information is on our signature cards, is that sufficient?

Answer: The CIP regulations require you to obtain and retain four pieces of information on individual customers, three on businesses. In addition, you must retain a record of the method(s) you used to verify your customer's identity. The rules do not, however, specify exactly how this is to be accomplished.

Some institutions are using separate forms on which they record the required CIP information. Others are merely pointing to the information they collect on other documents, such as the loan application, the deposit account application, the safe deposit contract. You could store an electronic record of a search of a third-party database, where you input the pieces of information you are required to collect, you could mark on your deposit account agreement or loan application how you did the verification, or you could have a separate, stand-alone record.

As long as you can produce the documentation, the format is up to you.

The original version appeared in the July/August 2003 edition of the Oklahoma Bankers Association Compliance Informer.

First published on BankersOnline.com 03/29/04