Re-CIP to Re-Open DDA Account?

Question:

DDA customer account auto closes because the balance went to zero. Customer comes in 2 days later wondering what has happened. Must they be re-CIPed to re-open their account?

Answer:

The account is closed; i.e. you no no longer have a contract. If this person does not have any other accounts with you, he is no longer a "customer" under the CIP regulation.

If this person wants to open a new account, then he is a new "customer" for the purposes of CIP. The fact that your bank chooses to assign a previously used account number has no effect.