I have the following in my BSA Policy ....
Identification of elderly or disabled persons who conduct reportable transactions:
• Certain elderly or disabled persons may not possess identification documents that would normally be considered acceptable by the Bank. Therefore, and only if no other form of acceptable identification is available, The Bank will accept as appropriate identification a social security, Medicare, Medicaid or other insurance card, along with another document that contains both the name and address of the patron (e.g.: an organization membership or voter registration card, utility or real estate tax bill).
• The document will only be accepted and the transaction concluded if the Bank is confident that the elderly or disabled patron is who he says he is.
• If the above conditions are met, the CTR should be completed with the words “elderly” or “Disabled” in Box 13, and the method of identification, such as “Social Security Card” and “(name of organization) Membership Card Only ID” in Boxes 14d-f.
• The above procedure shall also be used for elderly and disabled patrons when conducting reportable cash purchases of monetary instruments and completion of the Transaction Log.
My opinions are my own, and not that of my employer.