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#2002929 - 03/20/15 03:34 PM Do you collect identification "Issued Date?"
New Manager Offline
100 Club
Joined: Jan 2004
Posts: 136
I don't believe there is a CIP requirement to collect Issued Date when obtaining identification, only the ID number. Is there anyone who does not collect the Issued Date? Have you encountered any issues because of it?

We're revamping our CIP form.

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#2002948 - 03/20/15 03:53 PM Re: Do you collect identification "Issued Date?" New Manager
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
There is no such requirment. However, when we use a person's passport or driver's license as the verification of their identity, we do collect the issue date, as well as the more important expiry date(to show that the identity document has not expired), along with the state of issuance and identification #.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#2002951 - 03/20/15 03:54 PM Re: Do you collect identification "Issued Date?" New Manager
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Actually, you do if there is one. Look at 31 CFR 1020.220(a)(3)(B) which says required recordkeeping includes:

"A description of any document that was relied on under paragraph (a)(2)(ii)(A) of this section noting the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date"

http://www.bankersonline.com/regs/31-1000/31-1020-000.html#220

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#2002957 - 03/20/15 03:58 PM Re: Do you collect identification "Issued Date?" Ted Dreyer
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Thank you! I must be on auto-pilot today.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#2002958 - 03/20/15 03:58 PM Re: Do you collect identification "Issued Date?" New Manager
New Manager Offline
100 Club
Joined: Jan 2004
Posts: 136
Thanks!

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