If a customer presents a military identification card and has no other form of ID, it is my understanding is you cannot make a copy of Military ID's. What other forms can be used? This person does not drive and has no transportation to get to the DMV. He does have an expired TX DL but that is all.
How are smaller banks, say in the $200M asset size, managing compliance risk when diving into online account opening? I'm very concerned about CIP-CDD-EDD. I cannot fathom never obtaining a wet signature or seeing a check prior to accepting a deposit. Also, asking the CDD-EDD questions online is completely different than in person regarding getting a feel for the customer. Do most banks also open new accounts online for businesses, trusts, estates, etc? Is there a vetted software company that is preferred for this endeavor?
What does "Social Security number issued for randomized issuance:N" mean? In the past I have only seen "Social Security number issued for randomized issuance:Y...."
Is there a place where we can see a description of all response codes for Chex Systems?
We provide services non-account holders, as well as account holders. Our platforms require the creation of customer "folders" for all teller transactions. This means we capture CIP elements to create non-account holder folders to process those transactions.
As the USA PATRIOT Act requires the capturing of CIP elements for account opening only (as far as I understand), are we also required to post customer CIP notices at the teller stations as well for non-account holders? Logic would dictate that the answer is yes, because the same CIP information is being collected for both groups, and we practice our KYC and AML principles for both. (Non-account holders or "consumers" can launder money or finance terrorism just as easily, or more easily, as an account holder.)
However, the PATRIOT Act only requires the notices for account opening activities/locations. Technicality, I'm sure. But what is the right thing to do?
In the August 30, 2020, Weekly Banker Briefing there was a question regarding receiving scanned driver's licenses when customers open accounts online. The last sentence of the response said the financial institution must delete the copy or image after use. I don't see that in section 213 of the Economic Growth, Regulatory Relief and Consumer Protection Act. Where can I find information regarding the requirement to delete the image?
Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?
Our bank currently does not open accounts for Non-Resident Aliens (NRA). I have a new customer that has an ITIN for work only, and a work authorization that will expire at the end of the year. She says that she is a "permanent resident" but does not have a permanent resident card. She says that this Employment Authorization Document (EAD) is her "green card" and is the same thing as a "permanent resident" card. Do I need to worry with it, or just take her word and move on?
Are we required to get an updated photo ID on an existing customer when we open a new account relationship with them (i.e. a loan, DDA, savings, etc)?
We think we heard Brian Crow say, at TopGun Mar. 2020), that if we acquire a loan from a non-covered institution, that did not collect Beneficial Ownership certification from a legal entity borrower, we now must do so. I'm looking for citation of that requirement in Regs or guidance etc. We're about to do exactly that scenario.
I have a compliance question related to our CIP documentation process. An IRS SS-4 Form is typically a required document to verify the Employee Identification Number. We are asking if a company’s Tax Returns and Department of Revenue Letter can be used as substitute items in lieu of the SS-4?