Just when I am about to get everyone used to scanning DLs and business licenses, the head of IT comes up with a way to enter the name of the document we used to verify our customer's identity on our customer information system. While I am tickled that this information can be stored at that level, I am concerned that we might be missing the boat here. I am concerned that by doing away with our current procedures we are opening ourselves up to criticism. Are we required to maintain just the type of document we used or a copy or scan of the document itself? Has anyone had an experience where the examiners might have expressed an opinion?

According to the FAQs on the CIP Final Rule, you are not required to keep a copy of the identification document. See www.fincen.gov and click on BSA guidance. Then there is a link to the FAQs.

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Are we required to maintain just the type of document we used or a copy or scan of the document itself?

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Neither of these. You are not required to keep a copy of the document, but if you don't keep a copy you need more than just the type of document. Under the CIP regs you need type of document, any identification number on the document, place of issuance, and, if any, the date of issuance and expiration date. See subsection (b)(3)(i)(B) of the CIP regs.

We currently do both. We enter the information on our system, which meets CIP requirements, and we scan the identification. The scanned identification has been very helpful when identity is questioned.

So do we.