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.
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?
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?
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?
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?
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?
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?