CIP FAQs – Would it be acceptable to retain a description of the non-documentary verification method used in a policy or procedure instead of recording the fact that a particular method was used on each individual customer's record?

Compliance > BSA > FinCEN FAQs - CIP
Q:  Would it be acceptable to retain a description of the non-documentary customer verification method used (such as a consumer credit report or an inquiry to a fraud detection system) in a general policy or procedure instead of recording the fact that a particular method was used on each individual customer's record?
 
A:  Yes, provided that the record cross-references the specific provision(s) of the risk-based procedures contained in the bank’s CIP used to verify the customer’s identity.  (January 2004)
 

ADDITIONAL INFORMATION
This FAQ was excerpted from the Interagency Interpretive Guidance on CIP Requirements that can be found at the following link:  https://www.fincen.gov/sites/default/files/guidance/faqsfinalciprule.pdf
 

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