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#2205923 - 02/13/19 03:27 AM Collecting deposit account personal info
ckme Offline
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ckme
Joined: Sep 2002
Posts: 245
I just found out that my deposit team added fields to collect the “sex“ of customers opening new accounts. The purpose was to identify the customer so they can properly address them when calling. Any suggestions?

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Deposits and Payments
#2205927 - 02/13/19 11:30 AM Re: Collecting deposit account personal info ckme
rlcarey Online
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rlcarey
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Galveston, TX
As long as you are not using that information if they happen to apply for a loan, what is your concern?
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#2205948 - 02/13/19 02:14 PM Re: Collecting deposit account personal info ckme
John Burnett Offline
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John Burnett
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One concern is that, if you have the information in file, you're obliged to include it in Item 7 of the and CTR you file identifying that customer.
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#2205949 - 02/13/19 02:17 PM Re: Collecting deposit account personal info ckme
rlcarey Online
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rlcarey
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Galveston, TX
If you are scanning and storing copies of ID's you most likely have the information, whether you input it into your system or not.
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#2205958 - 02/13/19 02:31 PM Re: Collecting deposit account personal info ckme
John Burnett Offline
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If those scanned copies are for accounts opened via the web, you could be in violation of the law. The EGRRCPA provision specifically approving the use of scanned images of certain IDs for opening accounts other than in person includes a requirement that the scanned images be destroyed after being used to confirm identity for account opening purposes.
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#2205963 - 02/13/19 02:42 PM Re: Collecting deposit account personal info ckme
rlcarey Online
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rlcarey
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Galveston, TX
I can't wait to see the regulator's interpretation of that very poorly written section of the law.
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#2205970 - 02/13/19 03:19 PM Re: Collecting deposit account personal info ckme
John Burnett Offline
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John Burnett
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I agree, Randy. When I first read it, I had to scratch my head, wondering what the heck was supposed to be accomplished by that section of the EGRRCPA. Frankly, I wasn't aware there was a need for whatever was intended with that rule.
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#2213770 - 05/16/19 03:07 PM Re: Collecting deposit account personal info ckme
BSARocksagain Offline
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BSARocksagain
Joined: May 2010
Posts: 67
Maryland
Does anyone know the reason behind this reasoning? You don't have to delete the ones you collect in person but you do if they're submitted online at account opening? Is it because it was sent via their computer? But isn't it already vulnerable coming across the internet already, what difference does it make being in our core system?

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#2213772 - 05/16/19 03:11 PM Re: Collecting deposit account personal info ckme
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
You are asking us the reason that our Congress thought this was a good idea? I assume this is a rhetorical question smile
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