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#1998590 - 02/26/15 10:12 PM Acceptible ID Verification Document
NU Rhules Offline
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SE, Nebraska
Using documentary verification on a mailed in Driver's License from Delaware. It has the photo and expiration date. But there's a stamp in dark letters that days "Not for Federal Identification". What does that mean? Does that mean I can't use it for CIP? I've never seen a Delaware DL before.

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#1998591 - 02/26/15 10:15 PM Re: Acceptible ID Verification Document NU Rhules
Doug Hendrickson Offline
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#1999451 - 03/03/15 05:32 PM Re: Acceptible ID Verification Document NU Rhules
NU Rhules Offline
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Doug - Thanks. .......what?
That link speaks to Delaware's policy for issuing Driver's Licenses. In their program they issue either a license that is not "federally compliant" or is.

Now I need to know what they are talking about. Does anyone here know what "federally compliant" means and what law it is supposed to be associated with? Specifically, how is "federally compliant" supposed to relate to compliance with CIP for Banks? Is Delaware unique? I have never heard of this. If there was such an animal (status of being federally compliant), don't you think it would be cited in the BSA (Patriot Act)? I about fell off my chair.

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#1999456 - 03/03/15 05:37 PM Re: Acceptible ID Verification Document NU Rhules
Elwood P. Dowd Offline
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If you want some deep background, you can read up on The Real ID Act. I would be hard pressed to say what its present day impact is on banks.
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#1999461 - 03/03/15 05:43 PM Re: Acceptible ID Verification Document NU Rhules
NU Rhules Offline
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OK thanks guys. For CIP ID verification purposes does anyone here use a State (one of the first 13 I might add) issued DL that has "Not for Federal Identification" printed at the top? How about any of you Delaware bankers?

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#1999464 - 03/03/15 05:44 PM Re: Acceptible ID Verification Document NU Rhules
Elwood P. Dowd Offline
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If your CIP says you accept a "driver's license" you do not need to worry about any words of limitation that document might carry...
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#1999482 - 03/03/15 06:18 PM Re: Acceptible ID Verification Document NU Rhules
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I would like to chime in on the practice of having someone FAX or mail a copy of a drivers license as a form of "documentary" verification.

Technically it's not "documentary" because you aren't looking at the actual document. You are looking at a facsimile of a document. There is no way to determine if you are looking at an actual document or something that was "cut and pasted" prior to being Faxed or copied.

IMHO, the only way you can state you obtained "documentary" verification is if you have an employee or agent of the bank examine the actual document. Now that person can take a copy of it (for all the good that does...), and/or record the number, issue/exp. dates, and issuing agency as long as you record the required information when you accept documentary ID.

Just my 2 cents.
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#1999503 - 03/03/15 07:05 PM Re: Acceptible ID Verification Document NU Rhules
happyauditor Offline
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I agree with Princess Romeo. For documentary verification, you should be examining the actual document, ensuring it is not tampered with, appears legitimate, etc. In addition, using a driver's license as documentary verification, you should be comparing the photo on the ID to the individual sitting in front of you.
Last edited by happyauditor; 03/03/15 07:06 PM.
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#1999508 - 03/03/15 07:09 PM Re: Acceptible ID Verification Document happyauditor
Elwood P. Dowd Offline
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Hopefully you commented on the proposed due diligence regulation that would require banks to perform CIP using only a photocopy of the beneficial owners' identification...
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#1999513 - 03/03/15 07:16 PM Re: Acceptible ID Verification Document NU Rhules
NU Rhules Offline
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Thanks Everyone,
I went to the DHS web page to discover that this Act is mostly about gaining access to Federal facilities such as Airplanes. This is why FinCEN has not said anything about it (that I am aware of). See the linked DHS FAQ. It is helpful and explains why I have not heard about it. They (states) are just coming around. I even found info on our little 'ol state of NE's DMV page.
http://www.dhs.gov/real-id-public-faqs

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#1999516 - 03/03/15 07:27 PM Re: Acceptible ID Verification Document Elwood P. Dowd
happyauditor Offline
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Ken, sorry I must say I have not kept myself up to speed on the details of that proposed legislation and therefore, no, I have not commented...to examine copies of identification for "documentary" verification goes against common sense in my opinion.
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#1999564 - 03/03/15 08:48 PM Re: Acceptible ID Verification Document happyauditor
Elwood P. Dowd Offline
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Quote:
to examine copies of identification for "documentary" verification goes against common sense in my opinion.


Mine too. grin
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