Update Existing & Merged Customer CIP Information

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Question:

Does the Patriot Act require that national banks update existing customers and merged customer CIP information? Do we have to update customers with a P.O. Box as their physical address if they have had their accounts with the bank since before the Patriot Act was written or were customers with a merged bank?

Answer:

It is not required to update your data on long time customers as long as the bank feels it truly knows its customer. However, many banks do periodically update the customer information so that they have current information. You can take the opportunity if a new loan application is received or new deposit account is opened. In a situation where it was a mutual customer with a merged bank, it makes sense to bring in the complete set of information. It is the prudent thing to do to bring the most complete information into the combined file.

First published on BankersOnline.com 11/10/08