The bank I work for recently implemented a revised set of Patriot Act related procedures. As it now stands our options for address verification are limited to the following:

1. Phone book listing
2. Verfication through Information / 411
3. Current utility or credit card bill
4. Current vehicle registration
5. Customer relationship of more than 1 year with the address listed on the banks account profile matching the address provided by the customer.

While those are some good options for address verification, there are plenty of others that seem equally valid. (For example: US passport, state issued driver's license, county property records, current paycheck or any piece of postmarked mail - assuming they match the residential address given by the customer.) But those are not options for us. Even worse, there is no option for managers (at any level) to waive the verification of address (or more accurately, use other means of verification other than the approved methods listed above).

My guess is that in our effort to follow the letter of the law we have implemented restrictions that go way beyond what is necessary to be in compliance with CIP.

Whaddya think?

Thanks for your thoughts!

This is the part that I can't reconcile:

Quote:

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While those are some good options for address verification, there are plenty of others that seem equally valid. (For example: US passport, state issued driver's license, county property records, current paycheck or any piece of postmarked mail - assuming they match the residential address given by the customer.) But those are not options for us.

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The regulation allows for documentary methods of verification (verifying information against a DL, for example.) And this method is invariably less time consuming and less expensive than what you are doing now. Why would your policymakers tell you that this is not an option for your bank?

We are finding that many times the address on the license is different than the address the customer gives to us. We then have a discrepancy to resolve and are having trouble doing so when the customer is just moving to this area. This is our greatest obstacle. I would be interested in knowing whether this is an issue with other banks.

I would not be able to bank with you. I get my mail at the Post Office and I have an unlisted telephone number. I have nothing to hide. The neighborhood kids got in all the mailboxes when they were moved to the curb. We got an unlisted when we started getting weird phone calls at 3:00 a.m. intended for another person with the same name.

This is a great list for U.S. Citizens. What do you do for non resident aliens?

This is coming up almost on a daily basis. As there are several large new home developments in the area, we are getting our fair share of new customers coming in to open accounts under their new address while their id is still under the old one. We are asking for proof of new address with a utility bill, mortgage doc, lease, etc. We will also verify the address on their credit report as we pull credit for all new checking accounts. IF we didn't allow for these verification discrepency documents, we would be turning away a lot of new accounts.
Our other issue is the person coming in to open a joint account with someone who isn't or can't come in. Right now we are sending the person who is present away with a temporary sig card and a form for the other signer to complete and return along with a copy of their id.
I was in a competitor's branch the other day and they will not open add anyone on an account who cannot physically come into the branch with their id. Since a lot of our customers have family members from out-of-state on their accounts, this too would cause a big problem.
How is everyone else handling this? I'd appreciate anyone's comments.

We do as you do to verify addresses. The customer must produce something (mail etc) to verify their address.

If a customer needs a "take out" on the sig card, we require that the second signature be notarized. We bought stamps with the wording for the notary to complete and stamp it at the bottom of the card.

We also request a notary verification for out of state customers. Additionally we have a form that details the type of documentary evidence used for the identification the also must be submitted before the account is opened.