There is some discussion about the regulation in regards to obtaining and verifying the customer's identity for CIP. The regulation states "within a reasonable time after the account is opened." Almost everywhere I've been, it's been 45 days or accounts are closed unless approved by the BSA Officer, but I can't find anything that states 45 days or even defines what is a "reasonable time period". Is 45 days just a best practice or is there somewhere that gives the guidance of 45 days? Or is it just based on what is stated in the BSA Policy? I've had some tell me 30 days and others tell me 60 days. Thanks as always for your insights!

It has been a few years since I actively audited banks for BSA/AML compliance, but I cannot remember any of my clients that would even open an account before the CIP requirements were met. So, a 30 day versus 45 or 60 day period was never a consideration.

Craney, I'm not aware of any regulation that addresses this because as Rlcarey said, in theory you shouldn't be opening accounts without proper CIP. However, in practice, it's impossible, no institution on this planet has 100% compliance. So BSA programs typically monitor for CIP related issues and build in a remedy period to resolve CIP issues that are identified. My bank's program is 30 days. Mistakes happen, policy addresses it and gives a remediation period.

Yeah, I think we're looking at CIP Verification (i.e. driver's license, beneficial ownership, etc.) and giving the branches extended time to obtain the verification documents. Most of the information is gathered before the account is opened. I'm definitely wanting to shorten it, but I have been getting pushback. Thank you both!!