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.)