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#2243158 - 09/25/20 09:31 PM Record Retention Period for an ID Image
hsbs Offline
Junior Member
Joined: Feb 2020
Posts: 26
Hello,

Is there a regulatory retention period for an ID image for an online opened account? To rephrase it... if one of our customers opens a consumer account online (checking/savings account), and they provide us with a copy of their ID... is there a record retention period for the copy of the ID that is required by any regulation/rule?

Thank you all for your help.

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#2243159 - 09/25/20 09:37 PM Re: Record Retention Period for an ID Image hsbs
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,631
Galveston, TX
If they provided it during an online opening process, then it has to be deleted after the account is opened per S. 2155
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#2243162 - 09/25/20 10:12 PM Re: Record Retention Period for an ID Image rlcarey
hsbs Offline
Junior Member
Joined: Feb 2020
Posts: 26
Thank you very much, Randy.

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#2245464 - 11/12/20 09:05 PM Re: Record Retention Period for an ID Image rlcarey
DBouton Offline
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Joined: Jun 2010
Posts: 9
Randy

Does this apply only to credit unions?
Does this apply only to online account opening?
Last edited by DBouton; 11/12/20 09:06 PM.
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#2245466 - 11/12/20 09:34 PM Re: Record Retention Period for an ID Image DBouton
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,206
Illinois
Quote
Does this apply only to credit unions?


S. 2155 Sec 213(a)(4)

(4) Financial institution.--The term ``financial
institution'' means--
(A) an insured depository institution;
(B) an insured credit union; or
(C) any affiliate of an insured depository


Quote
Does this apply only to online account opening?


S. 2155 Sec 213 (b)
.--When an individual initiates a request
through an online service to open an account with a financial
institution or obtain a financial product or service from a
financial institution,
the financial institution may record
personal information from a scan of the driver's license or
personal identification card of the individual, or make a copy
or receive an image of the driver's license or personal
identification card of the individual, and store or retain such
information in any electronic format for the purposes described
in paragraph (2).
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#2245467 - 11/12/20 09:35 PM Re: Record Retention Period for an ID Image hsbs
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,631
Galveston, TX
Refer to Section 213

https://www.congress.gov/bill/115th-congress/senate-bill/2155/text

It applies to all financial institutions and this is all we have at the moment. There has been no additional regulatory guidance issued.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2245514 - 11/13/20 09:23 PM Re: Record Retention Period for an ID Image rlcarey
Joybell Offline
New Poster
Joined: Mar 2020
Posts: 1
Is this in effect now? If so when did it go into effect?

Thank you

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#2245516 - 11/13/20 09:42 PM Re: Record Retention Period for an ID Image hsbs
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,631
Galveston, TX
There is no effective date in the legislation so presumably it was effective the day the Act was signed.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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