Q: If the bank requires a customer to provide more identifying information than the minimum during the account opening process, does it have to keep this information for more than five years?
A: The bank must keep for five years after the account is closed, or in the case of credit card accounts, five years after the account is closed or becomes dormant, all identifying information it gathers about the customer to satisfy the requirements of § 103.121(b)(2)(i) of the CIP rule. 31 C.F.R. § 103.121(b)(3)(ii). This would include any identifying information, the bank will use, at the time the account is opened, to establish a reasonable belief it knows the true identity of the customer. So, for example, if the bank obtains other identifying information at account opening in addition to the minimal information required, such as the customer's phone number, then the bank must keep that information. (January 2004)