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#1816429 - 05/22/13 02:55 PM CIP, Copying ID, Drivers License
Sunshine Banker Offline
Member
Joined: Jun 2012
Posts: 80
Florida
There has been discussion to retain or not to retain the copy of the Drivers License? Any issues,concerns or critisism we may receive by retaining the copy. This question has been asked, but please refresh my memory regarding making a copy of the Driver's License for CIP purposes for opening deposit accounts. We make a copy, place in customer's file along with other account opening documents, File gets reviewed for CIP and completion of documents. We do not scan new account documents-original docs are retained at the location where account was opened in a secured area (lock and key).

On the loan side. A copy is obtained for CIP purposes, file reviewed, the copy of the license is pulled and retained separate in a secure area. Issues?

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#1816448 - 05/22/13 03:31 PM Re: CIP, Copying ID, Drivers License Sunshine Banker
Dr.Ozya Offline
Member
Joined: Mar 2013
Posts: 87
Phila
I've seen criticism of NY DFS for keeping a copy of DL on the loan file, since the underwriters and loan administrators can see the race and gender of the applicant/customer, and treat them differently before loan closes and during the sevicing or foreclosure. The bank ended up removing all copies from the loan files and restricting images on the system for lenders. Your approach seems to address that concern (unless your workflow shows that the underwriters review picture IDs as a part of their process).

FDIC was uncomfortable that for deposit files two forms of ID were stored together, so bank employees could potentially steal the identity. When the point was argued by the bank, FDIC agreed that other ways to comply with CIP program could be unnecessary cumbersome without reducing risks, and left that alone.

Other regulators or auditors I've dealt with had no problems with picture IDs.
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#1816578 - 05/22/13 07:02 PM Re: CIP, Copying ID, Drivers License Sunshine Banker
BC78a Offline
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BC78a
Joined: May 2006
Posts: 311
New York
Regarding the loan file issue, I had the same discussion with FDIC – Calf. about 10 years ago. They told us we could not keep a photo of the ID in the file due to fair lending. I suggested that they speak to the BSA examiners who loved that we kept a copy of the IDs. Their solution was for us to write on each ID “For Identification Purposes Only”
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#1816706 - 05/23/13 12:24 PM Re: CIP, Copying ID, Drivers License Sunshine Banker
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
This question does fall under the heading of "asked and answered." See footnote 49 on page 56 (document, not pdf) of the BSA-AML Examination Manual.
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