Vendor Guru Q&A - Compliance

Latest Compliance - Photocopies Topics

CIP Proof in the File

06/18/2007

Are we allowed to have picture IDs of customers in the loan files?

We currently take copies of picture ID when opening new accounts and place the imaged document on our mainframe. We do not have paper files. The question came up whether there are any Reg B violations since this info is readily available to the lenders. We have been through several OCC exams and nothing has been said but now I wonder if there are any problems having this available. From what I see, it is no different than having a paper file with the ID in it but I wanted someone else's opinion.

Copy of Drivers License in the Credit File

11/06/2006

At one time we were not to copy drivers license and put them into the credit file. I understand a recent interagency agreement has changed that procedure. Do you have any knowledge of the change?

Keeping Copies of Drivers Licenses with Loan Docs

03/27/2006

The financial institution I am at keeps copies of drivers licenses with the applicants' loan documentation. Should they be concerned about possible discrimination issues, because there is a picture of the applicant present when an application is processed for approval?

Keeping Photocopies of Sold Loans

02/20/2006

Are we required to retain photocopies of loans that were originated by us and later sold in a branch acquisition to another bank? If so, where do I find the requirements?

To Image or Not to Image, That is the Question

05/23/2005

Our bank is getting ready to start imaging loan documents. Where can I get some information about what documents we should keep originals of and not rely on images?

Identification of Totten Trust Beneficiaries

07/07/2003

Under the USA PATRIOT Act regulations and upcoming CIP, do we need to have photocopies of the driver's license and/or social security numbers for beneficiaries on a Totten Trust? In most cases, we never see the beneficiaries, as they are not signers on the account. Also, do we have to check them on OFAC?

Photocopy Of A Photo ID, Reg B, And "Discrimination in Lending"

02/03/2003

I understand that it is not a violation of ECOA to require an ID and photocopy it at loan closing. However, also I understood that taking a photocopy of a picture ID for a loan file is considered "collecting monitoring information" which according to Section 202.13 of Reg B is allowed only for credit secured by a dwelling. Aren't we setting ourselves up for "discrimination in lending" by keeping pictures of those we approve and decline in loan files?

New Account Procedures - Part I

11/01/1999

by Dana Turner

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Reg E Fraud- EFT Claim for Cash App

07/25/2021

During a review of the account, we noticed several transactions to Cash App, to the same people from last December and one in January. These were NOT disputed. Should we inquire about these transactions? If so, could we start our calculation from the statement date (plus 60 days) from the statement with the first unauthorized transaction? Does it make a difference that the December, the May and June transactions were on different cards? (The customer has had multiple cards.)

ACH Return for Unauthorized Debit

07/25/2021

Can a customer initiate an ACH Return for unauthorized debit from a closed bank account?

Reg E Telephone Transfers/Transactions

07/25/2021

I have a question about telephone transfers. The telephone transfers we perform are for the customer who calls the bank and requests the teller to withdraw from one account and transfer funds to another account. We currently have a custom form that a customer signs to perform ongoing telephone transfers and we keep this on file authorizing the bank to perform these transactions. We would like to discontinue using this form. Is this old form necessary and is it even a compliance requirement under Electronic Fund Transfer Act? We currently document on the transaction ticket "Telephone Transfer per Customer request". Any advice or information would be greatly appreciated.

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