Question:  We have a good CIP system for all accounts, including our commercial ones.  Do we still need to verify commercial depositor address every year?
 
Answer:  Yes.  Chapter 277 of the Texas Finance Code requires that a financial institution (which includes national banks and savings banks as well as state banks) verify with their commercial depositors that their required information (name, physical and mailing address, and driver's license number) are correct.  You could do this in a statement stuffer or as an information line on the statement.  For online customers, an email notification should be acceptable.