From the CIP section of the BSA Exam Manual.
A bank may keep photocopies of identifying documents that it uses to verify a customer's identity; however, the CIP regulation does not require it. A bank's verification procedures should be risk-based and, in certain situations, keeping copies of identifying documents may be warranted. In addition, a bank may have procedures to keep copies of the documents for other purposes, for example, to facilitate investigating potential fraud. However, if a bank does choose to retain photocopies of identifying documents, it should ensure that these photocopies are physically secured to adequately protect against possible identity theft. (These documents should be retained in accordance with the general recordkeeping requirements in 31 CFR 1010.430. Nonetheless, a bank should be mindful that it must not improperly use any documents containing a picture of an individual, such as a driver's license, in connection with any aspect of a credit transaction. Refer to Frequently Asked Questions Related to Customer Identification Program Rules issued by FinCEN, Federal Reserve, FDIC, NCUA, OCC, and OTS, April 28, 2005.
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