Originally, you wrote your CIP in 2003. Is it time to change? If you have any of the questions below, we will explore changing your CIP in light of new systems, processes and technology in 2021. Your program should shift with the new technologies and identifications in the market place. This program will look line-by-line at the regulation and point out avenues of change to explore in 2021. What does it mean to “know” your account holder? When do we have to ask purpose, source and anticipated volume questions? How can we enforce compliance with our program in our institutions? These questions are hard ones and the pending legislation on CDD doesn’t help. This program will evaluate CDD and EDD regulation, exam guidance and provide thoughts on how to proceed with a program that is sales friendly to the account holder. We look at the regulation line-by-line and what to expect with these changes.