Q. We have customers who had a loan with our bank. They paid off and a few months later we approved a new loan. We still have identification documents on file from the previous loan. Must we get new ID for the new loan? Or can we use the old documents? A. That depends on several factors. The Customer Identification Program rules require that you obtain the four pieces of required information and verify some or all so you can "form a reasonable belief that you know the true identity of the customer." Since your customer had an account with the bank and since the CIP rules require you to retain those records for five years after the account closed, you should have what you need on file.
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