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Physical Address Required for PO Box Exception?

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Question: 
CIP grandfathered customer (prior to 10/1/03). Customer has a PO Box listed, no physical address. Do we need to obtain physical address now that we have identified the PO Box exception?
Answer: 

Your CIP may indicate that you will not perform your CIP procedures on a pre-existing customer when he opens a new account, but the regulation does not use the term "grandfathered." If he does open a new account, it would be a best practice to obtain the information at that time, but you are not required to elicit additional information under any other circumstance.

First published on BankersOnline.com 7/15/13

First published on 07/15/2013

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