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A lender opening an account on a $312,000 loan collects 4 things: the applicant's name, address, date of birth and taxpayer identification number. For a bank subject to the cited customer identification program rule, does collecting these four identifying items complete the process or is verification also required?

Correct Answer

D) That is the 4-item minimum, and identity must still be verified after

A customer identification program collects name, date of birth, address and identification number, and then verifies identity through documents or non-documentary methods. Other choices: collection without verification is half the program; the employer name is not one of the four; and the identification number alone is not enough. See 31 CFR 1020.220. Source: 31 CFR 1020.220

Answer Options
A
That is sufficient on its own, as collection is what the rule requires
B
Only the taxpayer identification number is required for a US person
C
A 5th item, the employer name, is required before an account may open
D
That is the 4-item minimum, and identity must still be verified after

Why This Is the Correct Answer

A customer identification program collects name, date of birth, address and identification number, and then verifies identity through documents or non-documentary methods. Other choices: collection without verification is half the program; the employer name is not one of the four; and the identification number alone is not enough. See 31 CFR 1020.220. Source: 31 CFR 1020.220

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