We believe that if a former customer of the bank is opening a new account, your Customer Identification Program (CIP) should treat that customer as a new customer. While the CIP regulations define “customer” to exclude any “person that has an existing account with the bank,” a customer who has closed all accounts with the bank (and who therefore does not have an existing account with the bank) is not excluded and likely should be subject to your CIP procedures. 31 CFR 1020.100(c)(1)(i). While the CIP regulations that your policies can be risk-based, meaning that you could categorize previous customers as lower risks as other new customers, the regulations still require you to, at a minimum, collect and verify the required identifying information from the customer — (1) name, (2) date of birth (for individuals), (3) address, and (4) taxpayer identification number. 31 CFR 1020.220(a).

We also believe it would be a best practice to have customers who are opening new accounts to sign new signature cards and other account agreements. If the old accounts were closed, the old account agreements may no longer be valid, and your account agreements may have been updated since the time that the customer first opened an account with the bank.