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#1786014 - 02/14/13 03:12 PM CIP Question
CantBeShocked Offline
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Joined: Apr 2006
Posts: 260
We use a certain product for verifying CIP and ID on all deposit customers that creates a CIP form, scans the ID into imaged documents and performs an OFAC check. HOWEVER, if a loan officer opens a loan only (and not a deposit account), they do not use this software. They do verify the ID and get the OFAC check via Transunion. Because of the regulation on loans whereas you cannot scan the ID into the loan files, they are not getting a copy of the ID. Do we need to have them begin following the deposit steps - i.e. the CIP form, scan the ID, etc? OR - do we need to just follow through with scanning the ID only into a separate area other than the loan file to prove that we viewed and verified the ID? OR - is it necessary to scan the ID at all?

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#1786359 - 02/14/13 08:41 PM Re: CIP Question CantBeShocked
JackieN Offline
Junior Member
Joined: Mar 2004
Posts: 44
The regulation does not require you to scan/retain a copy of the ID. You just need to keep a record of it. Since you already use a CIP form for deposit customers, for consistency purposes,you may want to consider using the same form for loan customers with appropriate modifications made. Per the reg....

(i) Required records. At a minimum, the record must include:

(A) All identifying information about a customer obtained under paragraph (a)(2)(i) of this section;

(B) A description of any document that was relied on under paragraph (a)(2)(ii)(A) of this section noting the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date;

(C) A description of the methods and the results of any measures undertaken to verify the identity of the customer under paragraph (a)(2)(ii)(B) or (C) of this section; and

(D) A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.

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#1786526 - 02/15/13 01:49 PM Re: CIP Question CantBeShocked
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Because of the regulation on loans whereas you cannot scan the ID into the loan files,

There is no such regulation.

See Footnote 49 at the bottom of page 56 in the BSA/AML Compliance Manual for a detailed discussion of this issue. There is no real reason why lenders should have a different method for recording the identification they receive.
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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