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#2161558 - 01/23/18 08:13 PM ChexSystems Beneficial Owners?
J_G Offline
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Are we going to be able to do ChexSystems checks on beneficial owners in order to verify their identity?

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BSA/AML/CIP/OFAC Forum
#2161559 - 01/23/18 08:22 PM Re: ChexSystems Beneficial Owners? J_G
John Burnett Offline
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If ChexSystems will provide the information you need without its report being a consumer report as defined in the FCRA, yes. Otherwise, no, because you would need the BOs' written permission to do so.
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#2161569 - 01/23/18 08:47 PM Re: ChexSystems Beneficial Owners? J_G
J_G Offline
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How are most banks going to be verifying identities?

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#2161570 - 01/23/18 08:50 PM Re: ChexSystems Beneficial Owners? J_G
Cape Codder Offline
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By obtaining a photocopy of the BO ID, based on our existing ID requirements. We will use the eFunds ID Verification component for the OFAC screening.
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#2161571 - 01/23/18 08:55 PM Re: ChexSystems Beneficial Owners? J_G
J_G Offline
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And we can't use eFunds to do ID checks either, correct? Is it the same as ChexSystems?

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#2161599 - 01/24/18 05:30 AM Re: ChexSystems Beneficial Owners? J_G
JacF Offline

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eFunds IDV and Chex Systems are products of the same vendor, and often sold together, but they are not the same thing.

Chex is a consumer report, and was never intended as a CIP tool. IDV is a non-documentary verification service that was specifically designed with CIP requirements in mind.

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#2161611 - 01/24/18 12:24 PM Re: ChexSystems Beneficial Owners? J_G
Elwood P. Dowd Offline
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Quote:
How are most banks going to be verifying identities?


It's too early for anyone to claim he or she knows what "most" banks are going to do. The preamble to the CDD regulation indicates banks can use photocopies of identification. The preamble to the CIP regulation indicated banks are not required to verify all four pieces of information, just enough to establish a reasonable belief of the customer's identity.

There is no way to legally verify the name/TIN combination of a beneficial owner, but there is probably no need to either. Don't make this harder than it needs to be. Go with a photocopy of the identification and be done with it.
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#2161777 - 01/25/18 01:28 AM Re: ChexSystems Beneficial Owners? JacF
Buddy the Elf Offline
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Originally Posted By JacPCB
eFunds IDV and Chex Systems are products of the same vendor, and often sold together, but they are not the same thing.

Chex is a consumer report, and was never intended as a CIP tool. IDV is a non-documentary verification service that was specifically designed with CIP requirements in mind.


We are planning on using IDV as our non-documentary verification of Beneficial Owners.
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#2162065 - 01/26/18 05:11 PM Re: ChexSystems Beneficial Owners? J_G
BSAN3rd Offline
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We are currently checking TINs against LexisNexis to confirm that the SSN given by the UBO on the form matches the name - it's a quick check and quick save of the screen to show our work. That's as far as we are going with verification. If it does not match, we reach back out to the business line and let them know that the UBO did not provide accurate information and they need to follow-up and get it.

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#2162195 - 01/27/18 11:46 AM Re: ChexSystems Beneficial Owners? BSAN3rd
Elwood P. Dowd Offline
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Quote:
to confirm that the SSN given by the UBO on the form matches the name


Unless a bank is querying the IRS data base, that is simply impossible; there is no commercial product that can verify a name/SSN combination. As Social Security began randomizing the assignment of SSNs in 2011, the vendors' ability to even say when and where the number was issued is declining at a steady rate. Yet, the vendors keep selling the same old ____.
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#2162461 - 01/30/18 08:52 PM Re: ChexSystems Beneficial Owners? J_G
TryingtoComply Offline
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I agree with Ken. If the BO is not a signer on the account, just request a copy of their identification, document it and be done with it.
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