In this digital world, we are taking more on-line applications and do not see the borrowers until the loan closes. We are struggling with whether we should/could be asking the applicants to upload a copy of their driver's license at time of application so when we meet them at the closing, we can confirm the information on our CIP form matches the DL the person presents when they are signing the closing docs. Not sure if this is possible within our LOS, but we are thinking we would need to keep the copy of the DL in a place within our system that the loan underwriter cannot see it, correct? Does anyone else do this?

Just make sure are aware of the provisions in S 2155

(b) Use of a Driver's License or Personal Identification Card.--
(1) In general.--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).
(2) Uses of information.--Except as required to comply with
Federal bank secrecy laws, a financial institution may only use
the information obtained under paragraph (1)--
(A) to verify the authenticity of the driver's
license or personal identification card;
(B) to verify the identity of the individual; and
(C) to comply with a legal requirement to record,
retain, or transmit the personal information in
connection with opening an account or obtaining a
financial product or service.
(3) Deletion of image.--A financial institution that makes a
copy or receives an image of a driver's license or personal
identification card of an individual in accordance with
paragraphs (1) and (2) shall, after using the image for the
purposes described in paragraph (2), permanently delete--
(A) any image of the driver's license or personal
identification card, as applicable; and
(B) any copy of any such image.

This is exactly what I needed. Thank you!

At what point is "Deletion of image" required? Five years after they are no longer customers?

"(3) Deletion of image.--A financial institution that makes a
copy or receives an image of a driver's license or personal
identification card of an individual in accordance with
paragraphs (1) and (2) shall, after using the image for the
purposes described in paragraph (2), permanently delete--
(A) any image of the driver's license or personal
identification card, as applicable; and
(B) any copy of any such image."

Under that provision? It would be as soon as you used the image to identify the person and transcribed the information that you needed for retention purposes.