Is it true that with real estate customers we do not need to obtain primary id? We have alternative methods (ie credit reports, tax returns, statements, etc.) We just went through an OTS exam and they recommended that we input primary id on our customer information system files. Why don't we need that for our loan customers???

Thanks,

Duke

I assume that by primary ID, you mean photo ID of some sort? Section 326 requires that you verify enough information about your customer to form a reasonable belief that you know the true identity of the customer. You can use documentary or non-documentary methods to identify your customer. The regulatory agencies have an expectation that you do obtain a form of government issued, non-expired photo ID showing residence and/or nationality. If this is not possible, you may use other methods. Your CIP should address this from a risk-based perspecitve.