Answer:
Answer by Randy Carey: I think you would be pushing the definition of an account by treating an account that was previously charged-off as a banking relationship "to provide or engage in services, dealings, or other financial transactions".
Account means a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian, and trust services.
Answer:
Answer by Ken Golliher: CIP can be waived for "existing" customers, not "former" customers.
An examiner friend says his first CIP exam question is "Does the bank re-open closed accounts?" It's his most fertile field for finding CIP violations.
It's a lousy banking practice that has generated problems far greater than those related to CIP
First published on BankersOnline.com 7/9/12
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