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#1711149 - 06/15/12 09:23 PM Primary ID - photo exception
ABT Offline
Junior Member
Joined: Nov 2010
Posts: 32
Are there any financial institutions that allow in their CIP policy/procedures for an exception of a primary ID not to have a photo for religious reasons? If so, how is the exception worded?

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#1711153 - 06/15/12 09:26 PM Re: Primary ID - photo exception ABT
Gatorgirl Offline
Joined: Jun 2007
Posts: 55
How would you determine the ID belonged to the person in front of you? I would be concerned accepting something without a photo. How would these folks get a drivers license or a passport - a picture is required.

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#1711185 - 06/16/12 01:45 PM Re: Primary ID - photo exception ABT
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no regulatory requirement or practical necessity for obtaining photo identification.

Banks use other methods to verify identity when they are opening accounts online. Banks in states with significant Amish populations also frequently create exceptions in their CIP for people who do not have photo identification based on their religious beliefs.

You may draft your own language based on the tack you intend to take. In some cases, banks require a birth record and a verbal verification from a known "elder" in the local religious community. In some, the religious community issues laminated cards that identify the holder as a member of the religious community. Note too that some states offer "photo exempt" identification.

Whatever flexibility you may choose to offer in the way of photo identification, you may not waive or dilute the requirement to obtain a U.S. TIN from a U.S. citizen opening an account.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1711186 - 06/16/12 01:51 PM Re: Primary ID - photo exception ABT
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
I agree with Ken. A photo ID is not a requirement.

Just remember to reflect the process decided upon in the Bank's board approved customer identification program.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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