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#1752955 - 10/26/12 07:52 PM Photocopy drivers license
RPS Offline
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Can someone help settle this? Is it legal to make and keep in customer records a copy of a persons drivers license?

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#1755146 - 11/05/12 07:56 PM Re: Photocopy drivers license RPS
MyBrainHurts Offline
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Originally Posted By: RPS
Can someone help settle this?


Apparently, none of us can, since your question has been out there for 10 days.

Any BSA examiner is going to recommend policies and procedures to fully identify your customer, which for most of us translates as some documentary ID. Your fair lending examiner, finding a DL picture in your car loan files, will say you improperly gather information on race and ethnicity.

Good luck.
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#1755216 - 11/05/12 09:30 PM Re: Photocopy drivers license RPS
rlcarey Online
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Galveston, TX
The only ID that I am aware of that cannot be photcopied is military ID. You could always call your Secretary of State's office to confirm.
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#1768995 - 12/19/12 08:14 PM Re: Photocopy drivers license MyBrainHurts
Dave M_TCA Online
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Dave M_TCA
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Originally Posted By: MyBrainHurts
Your fair lending examiner, finding a DL picture in your car loan files, will say you improperly gather information on race and ethnicity.


Not it the Bank's policy states it is collected only for identification purposes. According to the CIP FAQ's from January 2004:

2. Can a bank keep copies of documents provided to verify a customerís identity, in addition to the description required under 31 C.F.R. ß 103.121(b)(3)(i)(B), even if it is not required to do so?
Yes, a bank may keep copies of identifying documents that it uses to verify a customerís identity. A bankís verification procedures should be risk-based and, in certain situations, keeping copies of identifying documents may be warranted. In addition, a bank may have procedures to keep copies of documents for other purposes, for example, to facilitate investigating potential fraud. (These documents should be retained in accordance with the general recordkeeping requirements in 31 C.F.R. ß 103.38.) Nonetheless, a bank should be mindful that it must not improperly use any document containing a picture of an individual, such as a driverís license, in connection with any aspect of a credit transaction. (January 2004)
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#1769149 - 12/20/12 02:00 PM Re: Photocopy drivers license Dave M_TCA
Bibliofiend Offline
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DuPage County, IL
From what I recall, you're okay if you keep the copy of the drivers license in the collateral file, not the credit file.
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#1802563 - 04/08/13 08:32 PM Re: Photocopy drivers license RPS
Penny Offline
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Our system allows us to image the DL which is available for our operations side to view but blocks the loan department.

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#1803084 - 04/09/13 11:22 PM Re: Photocopy drivers license RPS
Bibliofiend Offline
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DuPage County, IL
Penny, sounds like your bank may also provide electronic copies of Board reports!
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