Often in our Lending Department, the only type of ID they get is the customer's driver's license, but our policy requires two forms of ID - can a credit report be used as identification (either primary or secondary)?

http://www.fincen.gov/statutes_regs/guidance/pdf/finalciprule.pdf page 7, question 1 answers your question.... you can use that only if it is in accordance with your risk assessment and is documented in your CIP policy as a documentary method to form a reasonable belief that you know the customer.

Great, thanks!

A credit report is non-documentary identification.

What are others using as secondary ID, both documentary and non-documentary?

Our policy requires us to get two forms of ID even though CIP only requires one. Currently, we have the following listed in our procedures as secondary ID:
-Credit cards issued by well-known companies
-Utility bill
-Student identification card
-Employee identification card which has been issued by a known company and contains a photo
-Medicare Card, Visit the customer's place of business
-Compare identifying information provided by the customer against fraud and bad-check databases
-Obtain a Credit Report
-Send the new client a welcome letter

Well, I can tell you these are all non-documentary forms of identification and I would not label them as a form of ID.

Initially, banks requiring two forms of identification focused on one piece of primary identification (government issued, photo, and relatively hard to get) to verify most of the information. Then they asked for a second piece of documentary identification which served to confirm some of the information on the first. Over time, many banks have realized that a consumer report can confirm name, address, identifying number, and date of birth; i.e. all of the required information.

In addition, asking a few well chosen questions drawn from information on the consumer report offer more in the form of verification than any piece of documentation would. Pulling a full blown consumer report in connection with every potential deposit relationship might be cost prohibitive and would require training contact personnel in its proper use. However, if a consumer report is always pulled in credit situations there is no reason you cannot classify it as identification. Your file must indicate it was used for this purpose; i.e. a copy of a consumer report in a loan file does not prove it was used for identification.

If I do not know you and it's my responsibility to verify your identity, I would far rather have a copy of your consumer report than your drivers license any day.

When accounts are opened remotely, such as online, you will often see multiple non-documentary products used and the results compared against each other. A protocol is established and programmed that requires x elements to match to be a "pass" and rejects are bounced for manual review.

I have reviewed many CIP programs and one comment I must make is that banks sometimes will list documents they will accept as secondary ID without giving any thought to what elements or how many elements of ID the document verifies. For example, if you need additional ID and look at a credit card, you are validating the name. If you look at a credit card bill you can validate name and address. Point being, give some thought to what you are trying to accomplish.

Actually, the CIP regulations don't require even one ID. You can do documentary verification or you can do nondocumentary verification or you can do a combination of the two.

Thanks all. So what documents, etc are you all accepting as secondary ID?

Assuming personal account for a US citizen...The regs say you get Name, Birthday (edit I forgot!), Address, & TIN. (which doesn't mean they have to show you a SSN card) In your posts above you use the term Secondary ID. That confuses me, but I think you mean a form of Verification. As Ted says above, you are only required one form of verification. But your bank requires two. We require two forms of verification and typically get Current DL and any form of membership (usually on a card) that shows their name. This corroberates they have two pieces of ID with their name on it (credit cards, library cards, NRA membership card, etc). I suppose they could have stolen a wallet but we've never seen that happen. What Kathleen says is a good idea, but I think it's understood we are looking for verification that they are who they say they are. Showing two forms with their name on it with one being a Gov ID is good enough for us. But we don't spell out what we are checking. We also use Credit reports on loans sometimes as a non-documentary way. But remember the book says you have to document somewhere that this is what you are using for ID. Someone reviewing the file shouldn't have to guess or ask. Our training problem here is that the staff are so scared they are going to miss something, they get ID on everyone and everything. I figure with the regs being eyed to make this a requirement, I won't say anything and let the regs catch up to our practices.

Are most of you accepting an Alien ID card as primary, secondary or at all?

Define "Alien ID"?