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Under the Customer Identification Program (CIP), which scenario would require additional verification procedures beyond standard documentation?

Correct Answer

B) A borrower's identity cannot be verified through normal documentary methods and non-documentary verification is unsuccessful

Under CIP requirements in 31 CFR 1020.220, when a customer's identity cannot be verified through both documentary and non-documentary methods, additional procedures must be implemented, which may include refusing to open the account or file a SAR if warranted.

Answer Options
A
A borrower provides a valid driver's license but has recently moved and the address doesn't match
B
A borrower's identity cannot be verified through normal documentary methods and non-documentary verification is unsuccessful
C
A borrower is a foreign national with a valid passport and ITIN
D
A borrower provides a state ID card instead of a driver's license

Why This Is the Correct Answer

Under CIP requirements in 31 CFR 1020.220, when a customer's identity cannot be verified through both documentary and non-documentary methods, additional procedures must be implemented, which may include refusing to open the account or file a SAR if warranted.

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