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CIP Verification

CIP verification that explains each exception, proposes the fix your own procedure allows, and keeps the reason for examiners

CIP exceptions cleared in minutes, each with its reason and its sources on file.

See the demoBook a demo
See one case, screen by screen ↓
demo2minutesfrom Dana's proposal to Marcus's approval on Ahmad Rezaei's file, against a next-business-day reply
demo3.1%of proposals returned by a BSA Analyst over 30 days of sample files, each with a reason code
target100%of CIP exceptions recorded with the procedure step, the sources and two names
target0membershipsopened with an unresolved CIP field
In short

What is CIP Verification?

CIP Verification is a CIP verification solution for account opening teams at banks and credit unions. Agents compare each customer identification exception field by field across the ID document, the credit bureau and a non-documentary database, explain each discrepancy in plain words, and propose the resolution the institution's own CIP procedure allows. A Member Service Representative proposes, a BSA Analyst approves, and the record keeps the reason for examiners.

AI use cases in banking: a buyer's guide to agentic AI for bank and credit union operations →

Updated

The problem

Why CIP verification exceptions wait a day and say only "verified"

CIP verification asks four things of every new customer or member: a name, a date of birth, an address and an identification number, each verified by a document, a non-documentary source or both. Most applicants pass automatically. The rest land in a CIP exception queue: an address with a missing apartment number, a date of birth with the day and month swapped, a hyphenated surname, an ITIN instead of a Social Security number, someone who moved last month, a soldier with an APO address, an 18-year-old with no credit file.

Today a Member Service Representative reads vendor codes on four screens, compares them by eye and emails the BSA team with screenshots. The reply comes the next business day, and the applicant waits or leaves. Fields get fixed in the core to make the vendor pass, and the note says "CIP verified" while the reason lives in an email thread, if anywhere. The CIP rule asks for a description of how each substantive discrepancy was resolved, and examiners sample exactly those files.

typical60%of digital applicants abandon account opening at most, much of it at ID verification
estimated18%of new memberships raise at least one CIP exception at a credit union of the demo's size, about 32 a business day
Where the minutes go on one CIP exceptionestimated
By hand65 minutes
With the solution9 minutes
  • Reading vendor codes and comparing the application, ID and bureau screens by eye15 → 2 min
  • Working out which step of the CIP procedure applies10 → 1 min
  • Emailing the BSA team with screenshots and answering its questions10 → 1 min
  • Writing to the member for a confirmation or a document8 → 1 min
  • The BSA Analyst checking the sources before approving12 → 3 min
  • Writing the resolution and the record for examiners10 → 1 min

Estimated split of the MSR's and the BSA Analyst's working time on one exception, by hand and with the agents. It leaves out the overnight wait for the BSA mailbox and the time the member takes to reply. Our arithmetic, kept modest.

How it works

How a CIP exception moves

Seven agents compare every field across every source and propose the fix the procedure allows; an MSR proposes, a BSA Analyst approves.

What comes in
Exception in4 fields, 4 sources · application, ID, bureau, database
Agents at work
Application Reader agentapplication and ID
Then
Source Comparison agentevery field, explained
Screening agentOFAC and 314(a)
Then
Resolution agentcites the procedure step
Then
Member Request agentone confirmation
A person decides
MSR and BSA Analystthe MSR proposes; the analyst approves
What comes out
Resolution with its reason
Corrected member record
CIP record for examiners
One case, step by step

CIP verification for one member, screen by screen

Thursday, October 22, 2026, at the Westfield Road branch of Norrell Federal Credit Union in Dayton, Ohio. Ahmad Rezaei applies at Dana Whitcombe's desk for membership share savings and Everyday Checking with a $250 opening deposit. Dana scans his Ohio driver's license and the identity verification service returns refer: date of birth mismatch, address partial. Here is what happens next in the working solution.

  1. 0110:31 a.m.

    Four CIP fields across four sources, on one screen

    Dana Whitcombe · Member Service Representative

    File CIP-26-6814 opens on Dana's exception desk, due by 2:31 p.m., 4 business hours later. The agents have read the application and the license, pulled the credit bureau header and the non-documentary database, and compared name, date of birth, address and ID number across all four. Name and the SSN ending 6620 match. The address is a near-match and the date of birth is a conflict.

    “The day and month are swapped on the application, a typing transposition.”

  2. 02One click

    Every value opens its source passage

    Source Comparison agent

    Dana clicks the license's date of birth. The source opens: the Ohio driver's license image from document imaging, scanned by Dana at 10:27 a.m., with DOB 07/03/1991, 14 BIRCH LN, DAYTON OH 45409, issued 07/03/2022 and expiring 07/03/2030, and the document check that the barcode matches the front. The address row explains itself the same way: the license leaves out the unit, and Procedure 4.2 treats unit-number and street-suffix variants as the same address.

  3. 0310:37 a.m.

    One confirmation instead of a document

    Member Request agent, then Ahmad Rezaei

    The agent picks the one request that closes the file: a one-tap confirmation, because Procedure 4.5 lets a transposed day and month be corrected to the ID document's date when the member confirms it and an independent source agrees. Dana sends it through digital banking at 10:36. Ahmad answers from his phone a minute later with a one-time code, and the comparison runs again: the date of birth row reads 07/03/1991, Resolved.

    The proposal: correct the date of birth to July 3, 1991, which Ahmad confirmed (Procedure 4.5), and accept the address as the same (Procedure 4.2). Confidence 0.97.

  4. 0410:38 a.m.

    The MSR proposes, a BSA Analyst approves

    Dana Whitcombe, then Marcus Ellery · BSA Analyst

    Dana proposes the resolution with reason code DOB-TRANSPOSED. She cannot approve her own proposal; the button is disabled for her. Viewed as Marcus Ellery, the screen shows who proposed it, when, the reason code, and that approving writes the date of birth to the core banking system. Marcus can approve, or return it with a reason.

  5. 0510:40 a.m.

    Approved, written to the core, membership open

    Marcus Ellery · BSA Analyst

    Marcus approves at 10:40, 2 minutes after the proposal. Only then does the core banking system record 07/03/1991 as Ahmad's date of birth, and membership 4471208 opens. Ahmad leaves the branch with his accounts instead of waiting for a next-day email.

    Identifying information is kept five years after the membership closes; verification records until Oct 22, 2031.

  6. 06The rest of the morning

    Every CIP exception, by lane and clock

    Service Level agent

    Across 38 branches, the contact center and online, the exceptions sit in lanes: 8 need a proposal, 7 wait for the member, 6 wait for approval, 2 are escalated and 12 are resolved today. Each row says what the agents found and propose, with the procedure step: Mei-Ling Castellano's license says Castellano-Wu, the same name under step 4.1. A notice says the credit bureau answered slowly at 10:18 and 2 files were retried.

  7. 0710:44 a.m.

    One document for a recent mover

    Member Request agent

    Corinne Abernathy's license and the credit bureau show 818 Galloway St, Columbus; the database shows 2210 Wexford Ct, Apt 5B, Kettering since September 28. At 9:12 a.m. the agent asked her for exactly one document. At 10:44 she uploads a lease for the new address from October 1, the agent reads it, marks it Match, and the address is verified under Procedure 4.3.

  8. 08Online

    An ITIN applicant, verified by the procedure

    Resolution agent

    Valeria Montes Cruz applies online with an ITIN, a passport and no credit bureau file. The agents do not treat the missing bureau file as a conflict. They propose verifying with the passport, its number and country of issuance recorded, and an electric utility account at her address since June 2023, and recording the ITIN as the TIN, at confidence 0.95.

    Procedure 5.1: “An ITIN is the identification number.” No bureau file is not a reason to decline.

  9. 09Restricted

    When identity cannot be verified

    Gwen Halvorsen · BSA Officer

    Benedikt Saar's SSN ending 0937 belongs to another person born in 1958, at the credit bureau and in the database. The agents stopped the opening and proposed nothing (Procedure 6.1). Gwen can decline the membership or ask for a second ID in the branch; the SAR decision is recorded in the BSA case system only. The applicant and the branch see a neutral status, never the referral.

  10. 10For the examiner

    The CIP record in the rule's four parts

    Examiner Pack agent

    Ahmad's file is kept as 31 CFR 1020.220(a)(3) describes it: identifying information, with the date of birth corrected from 03/07/1991; the document relied on; the non-documentary methods and results; and the resolution of each discrepancy, with both names and times. It also keeps the versions that decided it, procedure BSA-PR-03 version 9 and Resolution agent v4.1 at threshold 0.90, and replays each step from 10:24 to 10:40.

Who it’s for

Built for everyone who signs a CIP exception.

Four people at Norrell Federal Credit Union who carry one exception from the desk to the exam: what their day looked like, and what it looks like now.

DW
Dana WhitcombeMember Service Representative · Westfield Road branch
Member Service Representative
Before
Opens 6 to 10 memberships a day at the desk. On a refer she reads vendor codes on four screens, emails the BSA team with screenshots, and the member waits for the next business day.
Now
Sees each exception as four plain rows with every discrepancy explained, sends the one confirmation the agent drafted, and proposes the resolution with its procedure step while the member is still at her desk.
ME
Marcus ElleryBSA Analyst · across 38 branches and online
BSA Analyst
Before
Approves 30 to 40 CIP resolutions a day from email threads, comparing screenshots by eye and replying the next business day.
Now
Opens each proposal with its sources, its procedure step and a checklist, approves or returns it with a reason code, and bulk-approves only address variants at confidence 0.95 or higher, each recorded separately.
GH
Gwen HalvorsenBSA Officer · Norrell Federal Credit Union
BSA Officer
Before
Owns the CIP procedure, the referrals and the NCUA exam, and finds files that say only "verified", with the reason in an email if anywhere.
Now
Decides referrals and potential OFAC matches herself, approves every procedure and threshold change before the agents use it, and releases a masked examiner pack built from four-part records.
HW
Hollis WebbInternal Audit · read only
Internal Audit
Before
Samples files every quarter and rebuilds what happened from core notes and email threads.
Now
Replays any resolved file as it was on the day, with the procedure version, the agent versions and both names, and exports it.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents compare every field across every source and propose the fix the procedure allows; an MSR proposes, a BSA Analyst approves.

Application Reader agent

Reads the application from the digital account opening platform and the ID document, front, back and barcode, from document imaging.

  • Never infers a value that is not printed
  • Marks a missing field as missing
Source Comparison agent

Pulls the credit bureau header and the non-documentary database, compares name, date of birth, address and ID number across every source, marks each match, near-match or conflict, and explains each discrepancy in a sentence.

  • Never changes a value
  • Never treats a near-match as a match without a procedure step
Resolution agent

Maps each discrepancy to a step of the institution's CIP procedure and proposes the resolution in one sentence, with its confidence and the step cited.

  • Proposes only what a procedure step allows
  • Below 0.90 confidence, asks a person instead of proposing
  • Never approves
Member Request agent

Chooses the one confirmation or document that closes the file, drafts it from an approved template, sends it through digital banking, reminds, and reads the reply.

  • Never sends without the MSR's approval
  • An edited message needs a BSA Analyst
  • Never mentions a referral
Screening agent

Runs OFAC and 314(a) checks on every applicant before opening and records the results, with the list dates, on the same file.

  • Never clears a potential match
  • Sends every potential match to the BSA Officer
Service Level agent

Orders the queue by clock, warns the owner an hour before a file is due, and escalates after 4 business hours.

  • Never reassigns an approval to the person who proposed it
Examiner Pack agent

Assembles the audit trail and the four-part CIP records into an examiner pack, with ID numbers masked.

  • Never includes a referral or SAR in a member-facing export
  • Release needs the BSA Officer
Member Service Representative

Proposes; a BSA Analyst approves. The agents propose; a named person decides.

Ask in plain words

Ask the agents about any file

Ask about an exception, a source, a procedure step or a clock. Every answer points to the source passage and the step.

Why is the address a near-match, not a conflict?

The street number, street name and ZIP code agree on all four sources; only the suffix ("Ln") and the unit ("Apt 2") differ on the license. Procedure 4.2 treats those as the same address.

Could this be a different person?

Unlikely. The SSN matches the bureau and the database in full and is linked to this name only; the license barcode matches its front; the only difference is a swapped day and month. If Ahmad had not confirmed, the file would need a second ID.

What will the examiner see for this file?

The record in the rule's four parts: what Ahmad gave, the license relied on, the bureau and database results, and how each discrepancy was resolved, with both names. The OFAC and 314(a) results sit on the same file.

Which procedure step is returned most often?

By share, step 5.2 (thin files): 3 of 47 returned in 30 days. By count, address variants (4.2) and recent movers (4.3): 4 each. For dates of birth (4.5), both returns were confirmed by phone, not in the app; the agents drafted a clarification for the BSA Officer.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The CIP exception desk: four fields, four sourcesAhmad Rezaei's CIP exception: name, date of birth, address and ID number across the application, the driver's license, the credit bureau header and the non-documentary database. Date of birth 03/07/1991 against 07/03/1991 is a conflict; "14 BIRCH LN" with no unit is a near-match under Procedure 4.2.
Every value opens its sourceThe license's date of birth opens the license image from document imaging, scanned at 10:27 a.m., with the barcode check: the barcode matches the front.
A one-tap confirmation from the member's phoneThe proposed resolution under Procedures 4.5 and 4.2, beside Ahmad's secure message confirming July 3, 1991 at 10:37 a.m. with a one-time code. The date of birth row now reads Resolved.
Maker and checker on the record changeViewed as the BSA Analyst: approve or return with a reason. Dana Whitcombe proposed it at 10:38 with reason code DOB-TRANSPOSED; the core record is not written until approval.
Resolved: membership open, record correctedApproved by Marcus Ellery at 10:40, 2 minutes after the proposal. Membership 4471208 is open, the date of birth is corrected in the core banking system, and the record's retention dates are set.
All CIP exceptions, by lane and clockCIP exceptions across branches, the contact center and online, in lanes with due times, what the agents found and the procedure step for each, search, filters and bulk actions.
One document for a recent moverCorinne Abernathy's lease for her new address, read on arrival and marked Match under Procedure 4.3, with a draft request for a current ID for an applicant whose license expired.
An ITIN applicant, verified by the procedureNon-documentary verification for an applicant with no credit bureau file: the passport and a utility record, the ITIN recorded as the TIN, citing Procedure 5.1 and 31 CFR 1020.220(a)(2)(i)(A)(4).
A service member's APO addressAn APO box accepted with his parents' home recorded as the contact address, at confidence 0.96, under Procedure 4.6 and 31 CFR 1020.220(a)(2)(i)(A)(3)(ii).
Approvals for the BSA AnalystSeven proposals waiting, one escalated past 4 business hours. The selected one shows the fields across the sources and a four-item checklist; three address variants under Procedure 4.2 can be approved together after reading each.
Identity not verified: a restricted referralAn SSN linked to another person born in 1958, so the opening stops and nothing is proposed. The BSA Officer declines or asks for a second ID; tabs show the neutral status the member and the branch see.
The CIP record in the rule's four partsAhmad's record under 31 CFR 1020.220(a)(3): identifying information, the document relied on, the non-documentary methods and results, and the resolution of each discrepancy, with the versions in force and a replay.
Reports for the BSA OfficerThirty days of sample files: exceptions by type and channel, median time from exception to approved resolution, the share resolved within 4 business hours, proposals returned by reason, and memberships opened with an unresolved CIP field.
Governance

CIP verification that is cited, checked and signed.

Only what your procedure allowsThe Resolution agent proposes only what a step of the institution's CIP procedure allows, and cites the step. When no step fits, or its confidence is below 0.90, it asks a person. Procedure changes are proposed, versioned and approved by the BSA Officer before the agents use them.
Maker and checker on every resolutionThe MSR proposes and a BSA Analyst who did not propose it approves; the maker can never approve the same file, in single or bulk actions. A member record is written to the core banking system only after approval, and edited member messages, threshold changes and pack releases need a second person too.
Every value cites its sourceEach cell on the desk opens the passage behind it, with the system and the time it was read. Each proposal cites its procedure step, and each list check carries the date of the OFAC or 314(a) list it ran against.
No tipping offReferrals and SAR decisions live in a restricted area for the BSA Officer and BSA Analysts. They never appear on member-facing views, messages or exports; the applicant and the branch see a neutral status only.
Masked numbers, kept five yearsSSNs, ITINs and ID document numbers are masked on screen; a reveal asks for a reason, lasts 60 seconds and is logged. Branch staff see their branch and the online queue. Identifying information is kept five years after the membership closes, verification records five years after they are made.
Versions, overrides and replayEvery agent has versioned instructions and a named model, and every file keeps the versions that decided it. An analyst who returns a proposal picks a reason code: EVIDENCE-INSUFFICIENT, WRONG-STEP, NOT-CONFIRMED or OTHER. Internal audit can replay any resolved file as it was on the day.
Configuration

Your CIP procedure and service levels, as settings

The clocks, thresholds and member messages every exception runs on are settings. Each change is a new version, and some need the BSA Officer.

SettingDefaultChoose from
A file is due4 business hours after the exception opens4 business hours · 2 business hours · 1 business day
Business hours9:00 a.m. to 5:00 p.m., Mon to Fri9:00 a.m. to 5:00 p.m., Mon to Fri · 8:00 a.m. to 6:00 p.m., Mon to Sat
When a file passes its timeEscalate to the BSA Officer and tell the branch managerOn · Off
Resolution agent proposes at confidence0.900.85 · 0.90 · 0.95 (a change is a proposal the BSA Officer approves)
Name similarity for OFAC review0.850.80 · 0.85 · 0.90
Member remindersAfter 1 and 3 business daysAfter 1 and 3 business days · After 2 business days · None
An edited message needs a BSA AnalystOnOn · Off (unedited templates send on the MSR's approval)
Accept a TIN from a third-party sourceOffOn · Off (the BSA Officer decides, under the FinCEN order of June 27, 2025)
Connections

Works with the systems account opening already runs on

Core banking systemmember and customer records, written only after a BSA Analyst approves
Digital account opening platformapplications from the branch, the contact center and online
Identity verification servicedocument checks and the non-documentary database
Credit bureauheader files, with a designed timeout, retry and fallback
Document imagingID images, leases and utility bills, every value cited to its passage
OFAC screening service and the 314(a) listSDN and non-SDN lists refreshed daily; 314(a) lists loaded by the BSA Officer
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
< 1hour
from a CIP exception to an approved resolution, against a next-day wait today
target
100%
of exceptions recorded with the procedure step, the sources and two names
Every exception
with its reason
target
0
memberships opened with an unresolved CIP field

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate (the time split, and the share of new memberships that raise an exception at a credit union of the demo's size) · “typical” = published figures (a published industry study of digital account opening: up to 60% of digital applicants abandon, much of it at ID verification). Rules named for context: the CIP rule, 31 CFR 1020.220 (USA PATRIOT Act section 326); the NCUA BSA program rule, 12 CFR 748.2; FinCEN's order on obtaining TIN information from a third party (June 27, 2025); OFAC regulations, 31 CFR Part 501; 314(a) information sharing, 31 CFR 1010.520. The credit union, people, files and identifiers named on this page are fictional: characters and sample data in the working solution.

Questions

What account opening and BSA teams ask about CIP verification.

What is CIP Verification?

CIP Verification is a CIP verification solution for account opening teams at banks and credit unions. Agents compare each customer identification exception field by field across the ID document, the credit bureau and a non-documentary database, explain each discrepancy in plain words, and propose the resolution the institution's own CIP procedure allows. A Member Service Representative proposes, a BSA Analyst approves, and the record keeps the reason for examiners.

What are the CIP verification requirements?

The CIP rule, 31 CFR 1020.220, asks for a name, date of birth, address and identification number from each customer, verified within a reasonable time by documents, non-documentary methods or both. The record describes the document relied on, the non-documentary methods and results, and the resolution of each substantive discrepancy. Identifying information is kept five years after the account closes; verification records five years after they are made. Credit unions keep a CIP as part of their BSA program under 12 CFR 748.2.

How does it resolve a CIP discrepancy, such as a swapped date of birth or a missing apartment number?

Each discrepancy is explained in a sentence and mapped to a step of your procedure. In the working solution, a license that leaves out the unit is the same address under step 4.2, and a swapped day and month is corrected under step 4.5 once the member confirms it from a one-tap message. When a document is needed, the agent asks for exactly one, reads it on arrival and compares again.

Can ITIN applicants, applicants with no credit file and APO addresses pass CIP verification?

Yes, by rule rather than by guesswork. Each situation has its procedure step and its non-documentary method: an ITIN with a passport and one independent source for the address, a thin file with the ID document, the database and a call-back to an independently sourced number, an APO box with a contact address recorded. An expired ID is never relied on; the agent asks for a current one.

What happens when a customer's identity cannot be verified?

The agents stop the opening, propose nothing and refer the file to the BSA Officer, who can decline it or ask for a second ID. Any SAR decision is recorded in the BSA case system only, and no referral appears on a member-facing view, message or export.

Can we accept a TIN from a third-party source?

It is a setting the BSA Officer decides, off by default. FinCEN's order of June 27, 2025 allows it for institutions supervised by the NCUA, OCC and FDIC when the CIP rule is otherwise met, and the Federal Reserve followed. The record says which way each TIN was obtained.

Do people stay in control of each decision?

Yes. The agents compare, explain, cite and propose; they never approve, never change a value, never clear a potential OFAC match and never decide a referral. The MSR proposes, a BSA Analyst who did not propose it approves, and only then is the member record written to the core. The BSA Officer approves procedure, threshold and settings changes.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents: your CIP procedure, your reason codes, your member message templates and a sample of past exceptions. It goes live once every quality gate has passed. We will walk you through it on your own exceptions first.

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See it on
your CIP exceptions.

We'll run CIP Verification on a sample of your own past exceptions and your CIP procedure.

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