I am trying to find out if any of you have procedures for documenting the identifying information obtained when opening account for a new customer that include documenting the issue date and expiration date of the ID obtained. It appears that the requirements include documenting this information "if any". Our loan system is set up to ask for this information, however, our deposit system is not and I am trying to determine what others are collecting.

Thanks,

Although our system is set up for both issue date and expiration date, we document the expiration date and the date the ID was verified (along with the identifying number, of course). This is directly entered into our system at the time of account opening and it is housed as a permanent record (info. can never be purged/deleted...you can only add a new record if info. needs to be updated for some reason).

I believe the law REQUIRES you to collect, record and retain the issue date and expiration date of the identification, if the identification has those elements. For example, NYS driver license has both an issue and expiration date, therefore you are REQUIRED to collect/record/retain that information. A credit card typically does not have an issue date, only an expiration date, therefore, if the particualr credit card only has an expiration date, you are REQUIRED to collect/record/retain that information.

I would agree with happyauditor. However, our 150 branches are located in TX and CA. Since neither DLs have an "issue date", that info. is not recorded. Although rare, if we are presented with an out of state DL that has an issue date, then it is recorded into our system.

Logically if the element does not exist, no requirement...if it exists, you are required to record/retain.

FYI - the California driver license does have an issue date. It's on the bottom of the DL below the signature.