Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network


    Site Map

    Our Sponsors


Compliance Gurus
Lending Gurus
Operations Gurus
Security Gurus
Marketing Gurus
eBanking Gurus

Print Friendly! Email This Article! Discuss NOW!

Patriot Act - Two Forms of ID to Open Account?
Answer by David Dickinson and Ryan Rasske, BOL Gurus

Question: Is the bank required to have 2 forms of identification to open an account? Our Compliance Officer says it is the legal requirement of the Patriot Act, however I cannot find where it is required, only recommended.

Answer by David Dickinson: You only have to get enough verification so that you are reasonably satisfied that the customer is who they say they are. This is the "risk based" part. Because of that, there are no hard and fast rules for this step. You don't have to verify all identification or even two of the four things. No where does CIP say how many forms of ID are required.

Answer by Ryan Rasske: David is correct, there is no regulatory requirement stipulating how many forms of identification your bank must obtain. In fact, your bank could decided not to gather any forms of documentation and rely solely on using non-documentary methods (e.g. Credit bureau) or use a combination of both. Regardless of the verification methods your institution decides to use, the most important step will be your ability to demonstrate to your regulators (1) what method (documentary and/or non-documentary) was used, (2) results of the method used, and (3) how any discrepancies where resolved. Strong record keeping of your verification process will help carry your program a long way.

First published on 5/2/05

Home | Compliance | Lending | Operations | Security | Marketing | Technology | eBanking
BOL Archives    Privacy Policy    Important Disclaimer   Recommend This Site !   Contact Us

BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.