102620 – Due Diligence: General Requirements: Alternative Procedures for Pre-Existing Accounts

Reporting financial institutions may apply

i. The due diligence procedures for new accounts to pre-existing accounts,

ii. The due diligence procedures for High Value Accounts to Lower Value Accounts, and

Where a financial institution chooses to apply one or both of these alternatives it may do so with respect to all its pre-existing accounts or, separately, to any clearly identified group of such accounts. A group of accounts may, for example, be those maintained by a particular line of business or those maintained in a particular location.

Where a financial institution chooses to apply the new account procedures to pre-existing accounts the rules that otherwise apply to pre-existing accounts, continue to apply. For example, the financial institution can still rely on the exception for reporting a TIN or date of birth if it is not in its records and is not otherwise required to be collected by domestic law. Similarly, it may rely on the residence address test if applying new account procedures to pre-existing Lower Value Accounts.