New Due Diligence Regulation and Appendix A

Appendix A is analogous to a “model form” in a consumer protection regulation; i.e. if you use it and complete it properly, your compliance is assured. If you modify it, what you absolutely cannot do is eliminate any of the information it requires. Expanding the information it requires, for example including a description of the identification used for each individual listed, should not be a problem.

Alternatively, you can eliminate Appendix A entirely. Gathering and storing the same information electronically is perfectly acceptable.

However you gather and retain the information, the certification of the individual opening the account is essential. If you use the paper form, that person will simply sign it. If you do not use paper to obtain the information, you still must have some method for obtaining the individual’s certification.

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Learn more about Ken’s webinar Customer Due Diligence! New BSA Regulation