CIP: A Two-Part Process
The Customer Identification Program (CIP) requirements have been in effect for over 20 years now and for most institutions they’re just something you do without giving it much thought. As we go into institutions and review their CIP procedures, we commonly see instances where the CIP process has broken down over time. CIP is meant to be a two-part process. You are to request certain information (name, address, date of birth, etc.) from the customer and then verify it using documentary or non-documentary methods. Most often that is accomplished by obtaining a driver’s license. In the real world, we see new accounts personnel requesting a driver’s license first and then just typing that information into the system. While this might save some time, doing so ultimately bypasses the verification portion of the two-part CIP process.
Kevin explains more in the video.
Published
2025/05/08

Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).