Banker's Compliance Consulting Blog

CIP: A Two-Part Process

Written by Kevin Edwards | May 8, 2025 3:55:37 PM

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