CIP Customer Identification Verification Checklist

Inspection checklist for verifying Customer Identification Program (CIP) controls at account opening, including collection and verification of name, date of birth, address, and identification number under 31 CFR 1020.220.

Inspection Scope and Account Opening Context

• Account opening event and product type identified
  Record the account type, channel, and opening date for the file under review.
• CIP policy version referenced for review
  Identify the internal CIP policy, procedure, or SOP version used for this account-opening review.
• Inspector confirmed review scope includes 31 CFR 1020.220
  Verify the inspection is being performed against the institution's CIP requirements under 31 CFR 1020.220.

Required Customer Identity Information

• Customer legal name collected
  Verify the file contains the customer's full legal name as required by CIP.
• Date of birth collected for individual customer
  Verify date of birth was collected for an individual customer where applicable.
• Residential or business address collected
  Verify the customer address was collected in accordance with CIP requirements and internal procedures.
• Identification number collected
  Verify the file contains an identification number such as SSN, TIN, passport number, or other permitted identifier as applicable.

Verification Method and Evidence

• Documentary verification used and documented
  Select the primary verification method used for identity verification.
• Identity evidence supports the customer information collected
  Verify the evidence reviewed reasonably supports the name, date of birth, address, and identification number on file.
• Exceptions or discrepancies were resolved before account opening
  Verify any mismatch, deficiency, or non-conformance was resolved or escalated before the account was opened.
• Verification completed within required timeframe
  Verify identity was verified within the institution's CIP timeframe for account opening and any provisional account controls.

Recordkeeping and Retention

• CIP records retained in accordance with policy
  Verify required CIP records are retained and retrievable per policy and regulatory requirements.
• Verification source documents or data captured
  Verify the file includes the source documents, system records, or verification results used to support the identity decision.
• Record retention period documented
  Enter the retention period applied to the CIP record in months.

Screening, Escalation, and Final Disposition

• Customer screened against government lists when required
  Verify the customer was screened against applicable government lists or sanctions/watchlist controls per institution procedure.
• Potential match or alert escalated appropriately
  Verify any alert, potential match, or exception was escalated to compliance or the designated reviewer.
• Final CIP decision documented
  Select the final disposition of the CIP review.
• Corrective action required for deficiencies
  Indicate whether any deficiency, non-conformance, or control gap requires corrective action.