CRCM practice question 19 of 35

Which of the following is an accurate statement according to the requirements of the customer identification program regulations?

Full set: 459 questions
Answer options
A: A bank must always require documentary verification of a customer’s identification
B: A bank may waive any part of the CIP requirements if senior management approves the waiver and there is a good cause
C: A physical address or a post office box is acceptable for any new customer
D: The bank’s CIP program must enable it to form a reasonable belief about the identity of the person Correct answer
Correct Answer:
D. The bank’s CIP program must enable it to form a reasonable belief about the identity of the person
Explanation

The fundamental purpose of the Customer Identification Program (CIP) rule, as mandated by the USA PATRIOT Act, is to enable the bank to form a reasonable belief that it knows the true identity of each customer. This is the core principle upon which all other CIP procedures are built. The program must include risk-based procedures for verifying identity, which may involve documentary or non-documentary methods, but the ultimate goal is to satisfy this "reasonable belief" standard.

Why Incorrect

A. CIP rules permit both documentary and non-documentary verification methods; documentary evidence is not always required.
B. The core requirements of a bank's CIP are mandated by federal regulation (31 CFR § 1020.220) and cannot be waived by management.
C. A physical address is required. A P.O. box is generally not acceptable as the sole address for identification purposes.

References

1. 31 CFR § 1020.220 - Customer Identification Programs for banks, savings associations, credit unions, and certain non-federally regulated banks. Section (a)(1) states the program must be designed to "Enable the financial institution to form a reasonable belief that it knows the true identity of each customer."

2. Federal Financial Institutions Examination Council (FFIEC). (2020). Bank Secrecy Act/Anti-Money Laundering Examination Manual. Section: "Customer Identification Program," p. 28. It explicitly states, "The CIP must include risk-based procedures for verifying the identity of each customer to the extent that it is reasonable and practicable. The procedures must enable the bank to form a reasonable belief that it knows the true identity of each customer."

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