I know I read somewhere that banks were allowed for CIP purposes to single out the elderly and allow different CIP documents as evidence of identification, so I wrote that into the policy. Now the president is afraid we are discriminating. Can anyone point me to where I read we can make this exception (due to the fact the elderly may not have driver's licenses, etc.)? Thanks in advance.

The regulatory citation for this is 31 CFR 103.121(b)(2)(ii)(B)(2). (If you read this citation aloud, it sounds like a Frank Sinatra song ) However, it is discussed in more detail in the Federal Register notices of the proposed and final rules in the Section by Section analysis.

Oh thank you! Thank You!

To quickly address the issue of discrimination, it is not discrimination if the different treatment is beneficial to the elderly person. A simple example is Senior Checking accounts with no balance requirements, free check printing, etc. Just make sure the age cutoff is not higher than the minimum age that someone is considered a "senior." This age may be defined by your state's law.

what are some of the discrimination agence the eldely