CIP: Record Retention For Business Account Information

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Question:

For CIP, do we need to keep actual copies of documentation used to identify a business (for example, Articles of Incorporation)?

Answer:

Under the current regulation, you do not have to maintain copies of documentary verification, including copies of business documents. You need to keep a record of what you looked at.

However, Treasury has indicated a willingness to reopen this question for comment, based on some criticism from a member of congress. There is a possibility that Treasury and bank regulators will agree to change the regulation to require copy retention.

First published on BankersOnline.com 07/14/03