Questions and Answers
Do we need to retain records on dormant accounts for purposes of the CIP regs?
The customer identification program (CIP) regulations do not contain any special provisions for deposit accounts that become dormant. With respect to deposit accounts opened on or after October 1, 2003, the law requires retention of records (a) of customer identifying information for five years after the account is closed, and (b) of verification information for five years after the record is made.
Your state law may provide a closure procedure for dormant accounts and this procedure may dictate when the five years with respect to customer identifying information begins to run. Absent state law procedures, your policies and procedures for dormant accounts should specify when an account will be formally closed.
(Posted: 07/10/2008)
