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#2259310 - 09/07/21 04:49 PM Driver's License Image on Core-Reg B Issue?
Timex Offline
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I have read the history of this topic, but I have not seen a definitive decision, so I'm hoping we can settle this for everyone. Our core system displays driver's license images we have uploaded in connection with each customer's CIF file. Our Operations side has been uploading the DL images in connection with new deposits. It was always my understanding that to comply with Reg B we should not have copies of DLs in the loan files, so we used to keep a separate binder of DLs. Now with imaging capabilities, the DL image appears for all inquiries. I checked with our core provider, and there is no way to prevent loan originators from seeing the DL images (it's either all images or no images). In this modern age of imaging and enhanced core systems, is there now any regulatory tolerance for these DL images appearing on all employee inquiries? If not, how are other banks complying with Reg B? Are other banks just not uploading any DL images?

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#2259311 - 09/07/21 04:56 PM Re: Driver's License Image on Core-Reg B Issue? Timex
InFairness, CRCM Offline
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Why do you need the images of the driver's licenses? Is there a reason you're not just retaining the state and license number? If you retain the images, and the loan officers/underwriters can see them, it will be hard to prove no one used the demographic information on the licenses in an inappropriate manner.
Last edited by InFairness, CRCM; 09/07/21 05:05 PM.
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#2259312 - 09/07/21 05:04 PM Re: Driver's License Image on Core-Reg B Issue? InFairness, CRCM
Timex Offline
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Used by tellers to verify identity when the person is at the window.

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#2259319 - 09/07/21 07:13 PM Re: Driver's License Image on Core-Reg B Issue? Timex
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What system are you using for imaging? I know that if you use Fiserv Director you can limit who can see certain images based on the doc type and the security group the user belongs to so a teller could see images that a loan officer couldn't.
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#2259321 - 09/07/21 07:26 PM Re: Driver's License Image on Core-Reg B Issue? Cowboys Fan
Timex Offline
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Jack Henry. I confirmed with them that is not possible before posting this question since that would have been the easy solution. I can't believe we are the only bank that scans DL images. If so, it was nice of Jack Henry to create a feature that we are the only bank to use.

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#2259323 - 09/07/21 07:40 PM Re: Driver's License Image on Core-Reg B Issue? Timex
rlcarey Online
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ID are scanned all the time into the system for teller use. The fair lending risk is minimal unless you have a rogue loan officer and I hope that you would have other methods to catch discriminatory lending. I would not lose a minute of sleep over it.
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#2259326 - 09/07/21 08:14 PM Re: Driver's License Image on Core-Reg B Issue? Timex
CompliantOkie Offline
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Agree with Randy. Our core has images of IDs on file and has for years. Never had a fair lending issue.

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#2259337 - 09/08/21 12:38 AM Re: Driver's License Image on Core-Reg B Issue? Timex
Rocky P Offline
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In many fair lending exams, the question was do the underwriters have access to drivers licenses. Since they were kept on the deposit rather than loan systems, the answer was no.
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#2259340 - 09/08/21 11:00 AM Re: Driver's License Image on Core-Reg B Issue? Timex
Inherent_Risk Offline
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I don't even think access is an issue. If you have underwriters going out of their way to look at driver's licenses while making credit decisions, the problem isn't the access, and the answer isn't reconfiguring your whole system to try and stop the access.

That said, I do think having an underwriting process that forces the underwriter to view a picture of the borrower in order to complete their decisioning process COULD draw some examiner scrutiny. If they have to do an inquiry in your core, and that will force them to see the applicant, I could see some examiner's having issues with that process.
Last edited by Inherent_Risk; 09/08/21 11:03 AM.
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#2259346 - 09/08/21 01:23 PM Re: Driver's License Image on Core-Reg B Issue? Inherent_Risk
InFairness, CRCM Offline
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Originally Posted by Inherent_Risk
That said, I do think having an underwriting process that forces the underwriter to view a picture of the borrower in order to complete their decisioning process COULD draw some examiner scrutiny. If they have to do an inquiry in your core, and that will force them to see the applicant, I could see some examiner's having issues with that process.

I've had two exams where something similar became an issue. One was MLOs having access to scanned drivers' licenses and the other was underwriters have access to social media information used in fraud screens for online applications for unsecured consumer credit. In both instances, the examiners wanted to know how ensured the lenders did not use the information, since they could see it.
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#2259349 - 09/08/21 01:57 PM Re: Driver's License Image on Core-Reg B Issue? Timex
rlcarey Online
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Right and every new customer goes through CIP too - so they see the individual's ID then whether they scan it or not - not to mention that I would think that during the application interview a loan officer might notice that the applicant was black or female or disabled that was sitting in front of them. The issue is not and never has been whether or not the information is available to them, it is solely based on whether they use it in a discriminatory manner. Unless an examiner can prove that is happening then everything else is just them beating their chests.
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#2259682 - 09/14/21 04:15 PM Re: Driver's License Image on Core-Reg B Issue? Timex
Annie Offline
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You may also want to check out the Economic Growth, Regulatory Relief, and Consumer Protection Act Section 213(b). This may impact you to the extent you open accounts online.

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