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