5. How should a bank verify the identity of a sole proprietorship that opens a new account, (such as an account titled in the name of an individual "doing business as" a sole proprietorship) when there are no documents or non-documentary methods that will establish the identity of the sole proprietorship?

In some states, sole proprietorships are required to file "fictitious" or "assumed name certificates." Banks may choose to use these certificates as a means to verify the identity of a sole proprietorship, if appropriate. However, when there are no documents or non-documentary methods that will establish the identity of the sole proprietorship, the bank must undertake additional verification by obtaining information about the sole proprietor or any other individual with authority or control over the sole proprietorship account -- such as the name, address, date of birth, and taxpayer identification number of the sole proprietor, or any other individual with authority or control over the account -- in order to verify the sole proprietorship's identity, as described in 31 C.F.R. ' 103.121(b)(2)(ii)(C).

31 C.F.R. ' 103.121(b)(3)(i)
Required records

1. Would it be acceptable to retain a description of the non-documentary customer verification method used (such as a consumer credit report or an inquiry to a fraud detection system) in a general policy or procedure instead of recording the fact that a particular method was used on each individual customer's record?