CIP FAQs – How does the record retention period apply to a customer who simultaneously opens multiple accounts in the bank?

Compliance > BSA > FinCEN FAQs - CIP
Q:  How does the record retention period apply to a customer who simultaneously opens multiple accounts in the bank?
 
A:  If several accounts are opened for a customer simultaneously, all identifying information about a customer obtained under 31 C.F.R. § 103.121(b)(2)(i) must be retained for five years after the last account is closed or, in the case of credit card accounts, five years after the last account is closed or becomes dormant.  All remaining records must be kept for five years after the records are made.  (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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