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#1938512 - 07/08/14 06:02 PM CIP and Loan Files
Carol C Offline
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I know there has been plenty of discussion regarding this the over the years, but are you or are you not to keep a copy of the borrowers DL that was used for CIP in the loan file.

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BSA/AML/CIP/OFAC Forum
#1938562 - 07/08/14 06:44 PM Re: CIP and Loan Files Carol C
Princess Romeo Offline

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It is strongly recommended that you do NOT keep a copy of the DL in the loan file because an examiner may make a presumption that the photo on the DL may have been used in a discrminitory fashion.

Never mind the fact that you HAVE to obtain Ethnicity, Race and Sex info for certain housing loans, the DL is seen as a no-no.
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#1938571 - 07/08/14 06:49 PM Re: CIP and Loan Files Carol C
edAudit Offline
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edAudit
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You are here

Never mind the fact that you HAVE to obtain Ethnicity, Race and Sex info for certain housing loans, the DL is seen as a no-no

But the analyst do not look at that info... right?
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#1938593 - 07/08/14 07:03 PM Re: CIP and Loan Files Carol C
NotDoneYet Offline
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Well, my last bank (FDIC regulated) it was a huge no-no. But at this bank (OCC) we keep copies in the loan files. The regulators have never said anything about it, but maybe because you can tell it was collected at closing.

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#1939191 - 07/10/14 12:20 AM Re: CIP and Loan Files Carol C
Elwood P. Dowd Offline
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Next to Harvey
BSA/AML Examination Manual (April, 2010) page 56 (document, not pdf):

Footnote 49 A bank may keep photocopies of identifying documents that it uses to verify a customer’s identity; however, the CIP regulation does not require it. A bank’s 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 the documents for other purposes, for example, to facilitate investigating potential fraud. However, if a bank does choose to retain photocopies of identifying documents, it should ensure that these photocopies are physically secured to adequately protect against possible identity theft. (These documents should be retained in accordance with the general recordkeeping requirements in 31 CFR 103.38.) Nonetheless, a bank should be mindful that it must not improperly use any documents containing a picture of an individual, such as a driver’s license, in connection with any aspect of a credit transaction. Refer to Frequently Asked Questions Related to Customer Identification Program Rules issued by FinCEN, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, and Office of Thrift Supervision, April 28, 2005.
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