Question: Can we photocopy drivers licenses and attach them to our signature card or application for an account? We had heard that such a practice could be considered discriminatory because the license has sex and race on it.
Answer: It depends. As you know, Regulation B and ECOA prohibit discrimination in any aspect of credit on nine prohibited bases, two of which are race and sex. In order to guard against discrimination, the law prohibits collection of information that could lead to discrimination. (So, for example, you cannot collect race and sex data except on loans where you are required to request the monitoring information.) How could any of this impact what you're talking about in the deposit arena? If the deposit account would have a credit feature (such as an automatic overdraft line of credit that the prospective customer automatically applies for when applying for the deposit account), that takes it into the credit realm and the Reg B/ECOA restrictions will apply. If there is no credit feature, and you can isolate these copies where they will only be viewed and used in connection with the deposit account, there should be no problem because while there is an equal credit opportunity law, there is no "deposit taking opportunity" law.
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