Can anyone offer any insight on how to perform CIP for a homeless U.S. veteran?

Well, you would have to apply your board approved CIP policy or if you decided to make an exception or change your policy, you would have to go back to your board.

Is he on the streets or is he in a homeless shelter program, or with the VA?

If he or she is homeless and has no documentation, try contacting Volunteers of America http://www.voa.org/veterans as they have a program to assist Veterans. Otherwise without a physical address or documentation, there is not much you can do for CIP, but then again, having a bank account is not this person's greatest problem.

If he or she is in a transitional shelter program, then he or she should have their ID Card issued by the US Department of Veterans Affairs and it has a photograph, ID #, and expiration date. You can use that ID Card for documentary verification, and the address of the shelter program for the physical address.

If such an ID is acceptable under their current CIP policy.

The ID is issued by a government entity, it is a form of military ID, and has a photograph and unique serial number. Hopefully no one writes a CIP policy that specifically limits documentary ID to Driver's Licenses and passports - but describes documentary verification in the same language as the regulation.



In the case of the VA Issued ID, it evidences nationality as in "United States".

PR - Don't be too sure. I have seen board approved CIP policies that laundry list the only acceptable ID's by name. I'm just saying, whatever they decide to do it has to conform to the current board approved policy.

I am not saying that a VA ID is not acceptable.

Assuming you are asking about an address (homeless), not identification, you can use the address of the next of kin or another contact individual. Veteran status would have no effect other than the possibility that he or she might have an additional form of ID.

The VA cards that I have seen does not evidence nationality and a person does not need to be a US citizen to serve in the military. The one below does not have a id number

http://cdn.themilitarywallet.com/wp-content/uploads/2012/12/veterans-identification-card-vic.jpg

The one below has a number (as used for health care)but no nationality

http://www.va.gov/health/images/20140224_VA-ID-Card-Front.jpg

Drivers Licenses do not have a nationality either. The "nationality" refers to the nation that issued the ID.

This is a bit of a sensitive topic for me since I am a volunteer with a non-profit that is working with homeless veterans.

Based upon the quote:

(1) For an individual, unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver's license or passport;

"Nationality or residence" I do not see where it can refer to issuing agency.

Believe me based upon the question asked I think all are trying to help the homeless vets but we also need to insure we follow the letter of the reg. or will be answering to an examiner who may or may not have our same opinions.

1. What address should be obtained for customers who live in rural areas who do not have a residential or business address or the residential or business address of next of kin or another contact individual? For example, is a rural route number acceptable?
Yes, the number on the roadside mailbox on a rural route is acceptable as an address. A rural route number, unlike a post office box number, is a description of the approximate area where the customer can be located. In the absence of such a number, and in the absence of a residential or business address for next of kin or another contact individual, a description of the customer’s physical location will suffice. (January 2004)

http://www.fincen.gov/statutes_regs/guidance/pdf/faqsfinalciprule.pdf

Thank you all for your comments - truly good points being made. Our Board-approved CIP policy does not specifically list the IDs accepted for documentary verification. I was hoping that the Veteran's ID Card could somehow qualify as a primary ID, but as it has been pointed out, it does not evidence nationality or address. I am still trying to ascertain if the inidividual lives at a shelter or is simply out on the streets. If he is living at a shelter, perhaps we can perform non-documentary verification, and by some miracle he can be tied to that address. I am normally the CIP enforcer to the letter of the law, but in this instance I can't help but remind myself that this scenario does not capture the spirit of the law.

Is there a way to find the address of next of kin?

or could you document an address based upon a letter from social worker (and of course get it into Board approved P&P)

This is not a sensitive topic for me. However, I would be willing to accept government issued evidence of prior service in the U.S. military as indicative of residence or nationality. I am aware that non U.S. citizens can enlist, but a non U.S. person can also get a drivers license so it's not a perfect indicia of residence or nationality either. Due diligence should include a question on nationality, but, like CIP, it also does not require proof of nationality. If he asserts U.S. citizenship and has ID issued by the VA, there is little or nothing to quibble about.

For me, the only issue is whether this specific form of ID would fit within the terms of my bank's current CIP. It must.

Banks oftentimes "verify" the address offered by the customer by writing sending a letter or thank you note. If the correspondence is not returned, the address is presumed valid. Something similar could be done here, writing the next of kin or relative a note indicating that this customer has used this address in opening a bank account. If someone wants to fuss about "privacy" have the customer approve the disclosure in advance.

Irony = A law enacted in response to the 9/11 terrorist attacks could be used to deny a bank account to a servicemember who responded to the call of duty in response to those attacks.

I would really like to twist the hair of any examiner that would fault a bank for using an ID Card issued by the Department of Veterans Affairs instead of a passport issued by the Department of State.

I mean...., really?

I really don't think there is even a colorable argument that it would be unacceptable unless it didn't fit into the terms of the bank's CIP. If an examiner said it wasn't acceptable I would give $1,000 to have a seat in the exit conference...

In a prior life we had a section in our policy for "reduced CIP" - situations when we would allow one ID or lesser type of ID, such as for elderly persons who no longer drive, HOA signers etc., and I am sure a homeless vet could be included in that grouping.
We were never criticized for it.