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#317119 - 02/15/05 11:09 PM CIP Exemptions for Elderly and Disabled Persons
Anonymous
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Can someone tell me where in the regulation it states that the above referrenced persons do not have to provide a photo ID for CIP purposes since they most likely will not have one.

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#317120 - 02/16/05 12:30 AM Re: CIP Exemptions for Elderly and Disabled Persons
Princess Romeo Offline

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Princess Romeo
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Quote:

Can someone tell me where in the regulation it states that the above referrenced persons do not have to provide a photo ID for CIP purposes since they most likely will not have one.



The CIP regulation does not mandate that anyone provide a photo ID. The regulation states that a financial institution must obtain certain pieces of information about a customer and must then verify that information through either documentatary or non-documentary verification methods or a combination of both.

The FDIC has a handy "Guidance on Customer Identification Programs" that they issued July 2004:

http://www.fdic.gov/news/news/press/2004/pr7904a.html

This guide outlines the elements that must be present in your CIP program. You can have a program that uses other methods to identify the customer, but your CIP must contain risk-based procedures for verifying the identity of the customer.
_________________________
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Regulations are a poor substitute for ethics.
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