The BOL article about Existing Customers is so helpful, but I am getting more and more confused. After Oct. 1, once we have verified the customer's identity and we can choose to not put the same customer through CIP again if they come in to open another account. But we are still required to keep records of how we verified their identity for each account, so we have to have documentation for account # 1 and account # 2. It seems to me that we have no choice but to do a CIP form per account to comply with the record keeping requirements. Is this correct?

I just answered my own question. It seems that we just need to retain the name, address, DOB and ident. #, which we would have on the signature card. But I am still open to input for other bank's procedures on existing customers.