Question & Answer

Question: I refer to Training Page # 19 in Vol. III, No. 12-"Alternate ID For Elderly/Disabled on CTRs"-I'm sending a copy of Administrative Rulings 92-1 and 92-2. It was emphasized to us that in order to use the forms of identification listed as acceptable, (Social Security or Medicare/Medicaid card, organizational membership card, voter registration card, utility bill, real estate tax bill, etc.) they must be listed as acceptable in the financial institution's formal written policy and operating procedures as identification for transactions involving the elderly or the disabled. And once they are written in, there should be no exception to the policy. You might want to pass this emphasis along to fellow bankers.

Why did you change the Treasury's example of Jesse Fleming from a non-customer to an old customer with nothing but a signature on file?"

Answer: We'll gladly pass along your suggestion and information. It's an important emphasis. Many thanks.

As for the change-Treasury's original example had Mr. Fleming coming into the bank where he has no account and instructing the teller to deposit $9,000 in cash into his granddaughter's savings account. We modified the Treasury's example slightly in order to focus on the question of identification. We had a problem with anyone other than the granddaughter making a deposit into her account. Having been sued (in a past life when I worked for a financial institution) by a customer whose account was "tampered" with in this fashion, deposits into "other people's accounts" were not permitted. I'm sure there are other financial institutions with the same rules. So I made Mr. Fleming an "old" customer with an "old" account that had only a signature on file and no other identification. Other than that change, everything else is as the OFE wrote it.

Copyright © 1993 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 4, No. 1, 6/93