I understand that identification of a non-customer when cashing a check is not a BSA/CIP issue but I am interested to know what other Banks' perspectives are on cashing checks for non-customers when the check is "on-us." BSA/USA Patriot Act may not apply but we are concerned with proper identification in order to mitigate risk of paying the wrong person.

Many forum questions relate to non-resident or non-citizen individuals but what about even out-of-state individuals. I would be willing to be 9 out of 10 Michgan bank tellers could not pick the valid Texas driver's license from a line up of 5.

The Bank wants to implement a policy of only cashing on-us checks for non-customers with a Michigan driver's license or U.S. passport. The Bank surveyed several other local banks and most said under very few or no circumstances will they cash a non-customer check, even if the check is "on-us."

Thoughts?

For non-customer "on-us" checks we require a picture ID, phone number and fingerprint to cash.

Generally speaking, we honor 'on us' checks presented by .. anyone with proper ID. We maintain both US/Canada and International ID guides at all branches for the tellers to reference when needed.

Since it is not often that an out of state ID is presented, it doesn't hold up the lobby much to verify the ID against the guide when a teller is faced with one.

An update to the guide is made every year and we pay a little less than $20 each for them.

You might get into some problems in refusing to honor a check drawn on you just because the payee is a non-customer. IMHO you should make every effort to identify the payee and honor the check. If you cannot identify the non-customer, then that's another issue. We go so far as to contact the maker if necessary to try and confirm identity and the validity of the check.

Couldn't this be considered a form of redlining...?

To restate what I said in another thread, your customer owes someone money and offers a check. It doesn't matter whether it is a payroll check or not, but let's hone in on a payroll check.

Is your customer thinking "I have paid for labor performed and certainly hope my worker will be back again tomorrow as they are already trained. They can pay rent and buy food for their family"? Or, are they thinking, "well, my bank is going to make my worker jump through hoops, possibly to the point where frustration will make them go work for someone else. Great, a job opportunity for someone and a training opportunity for me."

Is your proposed policy part of the problem or part of the solution?

Al

What about an OFAC check?