While I do believe they will be out soon, was that release dated Oct. 2002 or April 2003?

It was a joke. Sorry. I should have added the traditional as we have been expecting this for a long time.

I am still working on getting good representation from the bank I work for at the ABA seminar on Wednesday. I invited the Insurance Department and they do not think it will apply to them. I know the final rules are not out, but what do you think?

Now I'm really confused. Are the final rules out or not?

Not as of 10:00am EDT on 4/28/03.

And not out as of 11:00 am on 4/28/03!
Maybe we should report in hourly!

That was EDT, as well.

Quote:

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Maybe we should report in hourly!

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That could have a MAJOR impact on the "guess the post count" contest!

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That could have a MAJOR impact on the "guess the post count" contest!

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Bwaaa-haa-haa-haaa!!!! she laughs evilly...

They should be out prior to the ABA teleconference. Some of the more interesting changes from the proposal include:

o implementation by Oct 1; and

o no requirement to copy the documents you used to verify identity, although you will have to document and describe the documents you used.

AR.

This post is turning frivolous...
1:29 EDT-No CIP rules yet... just checking in.

Let us be neurotic for you. The BOL team is obsessively/compulsively checking for the CIP rules (just as we have been since SEPTEMBER -- argh!) and we'll let you know the moment anything pops up.

You guys are the absolute BEST! I think I'll go home now...
And MB, you are Tops!

Hey banker mama! I just got back from four months in Florida. I took my draft copy of the CIP with me, just in case the final regs came thru, so I could edit it and get it back to my Board like pronto. Amazing! Here I am back again, and still no regs. Dragged all that paper around for nothin'! My advice: vacation is for vacation; don't be messin' with no bank work when you can be seeing the Mouse Man!

I just received an e-mail from our rep at Bankers Systems that stated the rules would be issued tomorrow, April 30th.

I just spoke with a representative of the company facilitating tomorrow's ABA telephone seminar and this person indicated the materials were received this morning and will be e-mailed to all participants later today.

Post deleted by zaibatsu

I don't know what this has to do with CIP, but you'll be happy to know that I did take a day of vacation last Friday. And I didn't log on until about 8 PM, well after the work day was over.

One thing I want to see is the mandatory effective date. AR mentioned October 1 which will give us 5 months instead of the 6 we'd heard about. But without having to acquire the infrastructure to copy IDs it will be easier to implement. I hope there are no hidden requirements to address. I hate those unexpected little additions. I'll have to dust off and update the policy I was working on so many months ago.

I wonder how many of us will implement immediately or take our time up until the August - September time frame.

Oh No! Are you starting another CIP poll?

On the deadline for compliance with 326, the Oct 1 date was initially targeted in anticipation of a release date that would make for a 6 month lead time to comply. Unfortunately, the affected regulators, a group that is much broader than just the banking regulators, had some discussions that delayed the issuance of the regulation past March. I'm not sure there is an ability at this point to change the Oct 1 implementation as there is some hope of printing the reg in the Federal Register momentarily. If there happens to be some more significant delays, which I think is unlikely at this point, then perhaps the implementation date will get pushed back.

One other thing about the final reg that you might find interesting. Consistent with the proposal, the final reg requires banks to have procedures to identify customers that may be on a government provided list of known or suspected terrorists. There has been much debate on what lists count for Section 326 purposes, e.g., OFAC, FBI, FinCen 314 requests, etc. There are currently NO lists of known or suspected terrorists designated as 326 lists. Any such list distributed by the US that is to be used for 326 purposes will be conspicuously labeled as a 326 list, so there won't be any doubt about which lists you must use for this purpose. AR.

This morning I received an email from the ABA - The Insider Edition - entitled:
"ABA INSIDER SPECIAL EDITION FOR April 29, 2003: Summary of Final Rule under Section 326 of the USA PATRIOT Act (Customer Identification Program)."
Attached to it, is an 8 page pdf memo from John Byrne with the subject line "Preliminary analysis of the Final Rule under Section 326 of the USA PATRIOT Act (Customer Identification Program)."

I haven't read this yet, but it indicates the final rules go into effect 30 days after publication in the Federal Register but we will have until 10/1/03 to comply.

The 10-1 date is also what I am hearing. These rules should be released this morning. In hopes that a webmaster hit the upload key to early I have been to the regulatory sites this morning but haven't seen anything yet.