We are in the process of changing our procedures to allow the Matricular Card as a primary form of identification. There was discussion about issuing an ATM card to a non-account holder. I personally feel this adds liability and risk for the bank. Are other bank's permitting this and why as I thought it would be an issue with Reg E.

An ATM card has to be linked to an account (making it fall under REG E)..how can you issue a card without an account? Are you talking about a stored value card?

I apologize for not being clear. An account is established by one individual who wants 2 ATM cards, one to send to a relative in Mexico to use. This is an issue in my opinion as the other card is not going to an account holder.

If the 2nd person is not a signer on the account I would not issue the debit card. There is too much risk involved.

I'm not sure why the Matricular card is mentioned here. It is moot to the scenario.

I would never recommend this. If there is an unauthorized withdrawal, how will you ever investigate it? You are telling your customer it is OK to give the card away and provide others with access.

And from a BSA standpoint, you'd be monitoring the heck out of an account with deposits in the US and withdrawals south of the border. These may be done on a regular basis and what will you do when the amounts grow and grow?

I would say this is a bad idea.