Q: Does the original information obtained during account opening have to be retained or can the bank satisfy the recordkeeping requirement by just keeping updated information about the customer, i.e., the customer’s current address?
A: The CIP rule requires that a bank retain the identifying information obtained about the customer at the time of account opening for five years after the date the account is closed or, in the case of credit card accounts, five years after the account is closed or becomes dormant. 31 C.F.R. § 103.121(b)(3)(ii). Updated information serves valuable, but different, purposes. (January 2004)