Sorry to post anon, I'm not at work and cannot remember my password, and I don't post very often.
If you haven't gotten this far in reading the guidelines, here's a preview.....Page 34 of the FFIEC BSA/AML Examination Manual released on June 30, 2005, Footnote 40 in the Recordkeeping Requirements and Retention section specifically state that “Banks are not required to make and retain photocopies of any documents used in the verification process. However, if a bank does choose to do so, it should ensure that these photocopies are physically secured to adequately protect against possible identity theft. In addition, such photocopies should not be maintained with files and documentation relating to credit decisions to avoid any potential problems with consumer compliance regulations .” (emphasis added)

How's that going to work with imaged files, I wonder?

Do we need to delete the copies of ids from our loan imaged files? I mean if the customer is seating in front of you, you going to be able to guess their race and gender.

This seems to contradict the CIP Q&A's which said you can keep copies (it didn't say anything about not keeping them with loan files). It only warned that the info should not be used in a discriminatory manner (duh!).

However, I have always said that you don't want to keep them there anyway. You want to keep CIP records in a centralized place so that they are accessible by all departments of a bank - deposit, trust, etc. so that CIP records can be reviewed as necessary.

We have been told that it is fine to image DLs. We maintain them at the client level and not the account level so it is not an actual part of the loan file. This process has proved very valuable in certain situations such as when you have concerns about a client.