Can anyone direct me to where in the CIP rule/FAQs/guides it states that we cannot accept photocopies of IDs to verify a new customer's identity? (This question is not referring to beneficial ownership.)

I don't know where it says that, but it must be the gospel.

From Question 4 on the April FAQ:

For example, a covered financial institution’s policies and procedures may state that the institution will accept photocopies of a driver’s license from the legal entity customer to verify the beneficial owner(s)’ identity if the beneficial owner is not
present, which is not permissible in the CIP rules. (Emphasis supplied)

Thank you, Ken! Yes, that's the FAQ that triggered my question of where it states in the CIP rule that we cannot accept photocopies of ID to verify an individual's identity. I guess it's an implied rule within CIP.

I used the because there is no "sarcasm" font. I really do not know of any basis for FinCEN saying that banks cannot use a photocopy as a documentary source of verification for CIP.

The CIP regulation clearly allows each bank to identify what types of documentary verification it will accept. It does not say the bank must require the "original" document. The preamble to the original CIP regulation acknowledges that banks may not have the ability to examine the original documents and uses that observation as a springboard for suggesting that more than one form of verification should be used.

In my opinion, the statement in Q4 is completely baseless. FinCEN gets to say what the rules are, but it has to be consistent with what it has said in the past. (Hence, the indecision and turmoil over beneficial ownership and automatically renewable time deposits.)

Does anyone require consumer loan applicants (non-real estate applicants) to sign a W9 form stating the SSN they provided is true and accurate? We currently have our portfolio applicants sign one, but our indirect applicants do not. We do not require an applicant to provide a SSN card at account opening. The only verification of an SSN that may happen is when an applicant's credit report is pulled and it may or may not track for matched SSNs.

Why would you require a W-9 on consumer loans. What purpose does it serve? The certification is meaningless as you have no information reporting responsibilities on consumer loans.

I agree - it is something we "have always done". It didn't make sense to me either - I just wanted another opinion. Thank you!