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#2079465 - 05/19/16 07:59 PM Copies of Driver's License in Loan Files
Vive Accommodare Offline
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Vive Accommodare
Joined: Apr 2013
Posts: 581
Compliance
Call me old fashioned, but I have a huge issue with a driver's license copy being in a loan file. I realize a borrower must present sufficient evidence of their identity, etc., but does anyone know where it states we would not keep a copy of the driver's license in the loan file?
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#2079496 - 05/19/16 08:57 PM Re: Copies of Driver's License in Loan Files Vive Accommodare
Dog Lady Offline
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Joined: Dec 2015
Posts: 74
We do not keep copies. I imagine any guidance either way would only be covered by the appropriate state.

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#2079497 - 05/19/16 08:59 PM Re: Copies of Driver's License in Loan Files Vive Accommodare
David Dickinson Offline
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David Dickinson
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Central City, NE
If you do a search, you'll see that we discuss this topic nearly every week. See footnote #49 in the BSA Exam Manual.
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David Dickinson
http://www.bankerscompliance.com

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#2079656 - 05/20/16 06:13 PM Re: Copies of Driver's License in Loan Files Vive Accommodare
Vive Accommodare Offline
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Vive Accommodare
Joined: Apr 2013
Posts: 581
Compliance
I'm always posed with the argument "we're a mortgage company, not a bank!" Which never helps my argument
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#2079667 - 05/20/16 06:35 PM Re: Copies of Driver's License in Loan Files Vive Accommodare
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Personally, I don't like the practice, because there are some restrictions on copying some forms of photo IDs. For example, you can certainly examine and take notes on information from a U.S. military ID card, but it's illegal to copy them. In Indiana, you can't make a color copy unless you stamp it to identify it as a copy. There are enough problems or special rules that it makes more sense, really, to examine the ID and copy information from it.

But other than those special limits on photocopies, there isn't a general ban on putting them in credit files. I'd only be concerned if you had a lender check out one of the copies and then take an adverse action on an application from the individual whose license he looked at -- and had no legit reason for the denial.
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