Welcome to the on-line
August-2004 issue of the
Community Bankers' Advisor
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The Advisor is prepared by attorneys at Olson & Burns P.C. to provide information pertaining to
legal developments affecting the field of banking. In order
to accomplish this objective, we welcome any comments our
readers have regarding the content and format of this publication.
Please address your comments to:
Community Bankers' Advisor
c/o Olson & Burns P.C.
PO Box 1180
Minot, ND 58702-1180
olsonpc@minotlaw.com
Also, visit our web site at:
www.minotlaw.com
The attorneys at Olson & Burns represent a wide
range of clients in the financial and commercial areas.
Our attorneys represent more than 30 banks throughout North
Dakota. |
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On January 8, 2004, the OCC issued a bulletin announcing that a “Frequently Asked Questions” publication had been produced for guidance regarding the Customer Identification
Program rule. We reprinted the first two portions of the FAC in earlier issues.
The balance of the publication is printed below.
FREQUENTLY ASKED QUESTIONS:
Final Customer Identification Program Rule
(Reprint of OCC 2004-3 Attachment)
31 C.F.R. § 103.121(b)(3)(ii) – Retention
of records
1. 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?
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.
2. 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?
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