Answer:
In the new revised CIP Chapter in the FFIEC Exam manual, “The CIP rule provides for an exception for opening an account for a customer who has applied for a tax identification number (TIN) and an alternative process for obtaining CIP identifying information for credit card accounts.
· The exception permits the bank to open an account for a customer who has applied for a TIN, but does not yet have a TIN. In this case, the bank’s CIP must include procedures to confirm that the application was filed before the customer opens the account and to obtain the TIN within a reasonable period of time after the account is opened.16
· For a credit card account, the bank may also obtain CIP identifying information about the customer by acquiring it from a third-party source prior to extending credit to the customer.”
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