Customer Identification Program (CIP): Four Mandatory Verification Elements
An individual walks into a broker-dealer branch office seeking to open a cash trading account. Under the USA PATRIOT Act and FINRA Rule 2090/CIP rules, which four pieces of identifying customer information must the firm obtain prior to opening the account?
CIP mandates 4 elements: (1) Name, (2) Date of Birth, (3) Physical Address (no P.O. Box alone), and (4) Taxpayer ID (SSN/ITIN).
Complete Analysis & Legal Rationale
Under Section 326 of the USA PATRIOT Act and federal broker-dealer anti-money laundering regulations, every firm's Customer Identification Program (CIP) must obtain four core pieces of information before opening an account: (1) Full Legal Name, (2) Date of Birth (verifying legal age of majority), (3) Physical Residential or Business Street Address (a P.O. Box alone is unacceptable; APO/FPO or next-of-kin address permitted only for military personnel), and (4) Taxpayer Identification Number (Social Security Number for U.S. citizens or passport/alien ID for foreign nationals).
Distractor Autopsy (Why Other Options Are Traps)
FINRA exam writers design incorrect distractors using specific calculation mistakes and regulatory misconceptions. Review why each option succeeds or fails:
These are the four statutory CIP pillars required by the Bank Secrecy Act / USA PATRIOT Act.
Bank routing numbers and credit scores are not mandatory statutory CIP opening elements.
Personal references and net worth statements are not required identity verification items.
Income and investment experience pertain to suitability under FINRA Rule 2111, not statutory identity verification.
Official Standard: Mandates collection of customer name, tax identification number, residential address, and date of birth.