CIP Rules & Photo ID

Question:

In regard to the proposed CIP rules, how do we handle an existing customer who refuses to provide photo ID when opening a new account? We know the customer because we have dealt with him/her for years.

Answer:

Under the proposed rules, you would have a BSA record retention violation if you left the account open. If it was deemed negligent, I believe the penalty is $500. If it is willful (I think it would be), the penalty is $1,000 and its a criminal act. In short, you would close the account.

Please don't think or do anything about this until the final regs are issued. Then, even without Paul Harvey, we'll all know the rest of the story.

First published on BankersOnline.com 12/2/2002