Anytime a bureaucracy can create extra work for law abiding organizations or people, they usually do. This rule should apply to the custodian, and any RIA acting as a custodian of client funds. Every (legitimate) custodian (Schwab, TD, Raymond James, Fidelity, etc.) already has identification processes in place. It seems the SEC would be better off enforcing this rule on custodians, as they are ultimately the ones harboring the laundered/ill-gotten funds that the proposed rule aims to stop. I haven't read of many instances of illegally gotten funds going through legitimate custodians because of the processes they already have in place. Again, work on fixing the smaller custodians that aren't adhering to CIP programs. Don't burden RIA's with another process if they're utilizing a custodian that has a legitimate CIP program already in place. It duplicates the work with the same effect.