Customer Identification Documents
Question: What copies can or should we make of documents that were used to identify customers?
Answer: There is a great deal of confusion about this, because the final rule is different from the proposed rule. On one hand, the rule would like as much documentation as possible. But on the other hand, you must account for the ECOA's concerns about the use of information to discriminate. Any customer identification program must comply with Regulation B's restrictions on information gathering. That means no pictures of the customer in loan files. It also means no copies of documents that might contain information about the customer's gender or race. You may have different documentation requirements for deposit accounts - requiring copies of picture identification documents - than you use on the lending side. If you do this, be sure to keep the deposit files totally separate from the lending files.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 13, 11/04
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