We're adding the hardware to capture and retain images of customers & ID documents (basically, cameras & scanners in every branch).

This morning, the employee who sets up security & access levels asked if lenders and underwriters should be allowed to view the captured images. From a conservative, fair lending perspective, I'd have to say no - using the same logic as not allowing copies of the driver's license in the loan file.

However, I know there are other banks out there with this technology. What do you do in terms of lender access? (This is a particular concern in the smaller branches where the branch manager / local lending officer also runs a teller window from time to time.)

I don't think that allowing loan officers access to viewing the images is the problem. The question becomes, what legitimate reasons would a loan officer have for viewing an image and how do you control that?

I don't see a problem with allowing lenders access to the images, especially in situation where the lender has other responsibilities. AFter all, verifiying someone's appearance vs. their purported DOB, verifying signatures, etc, are all good security practices. Fraudsters get loans as well as deposit acccounts.

Bart: This is an issue that should be addressed in your Information Security Program. Access controls on this information can be placed to restrict these records to those with a "need to know".

Your policy should state they collect it, but don't use it except for permissible reasons.

From the CIP proposal:
Treasury and the Agencies emphasize that the collection and retention of information about a customer, such as an individual’s race or sex, as an ancillary part of collecting identifying information do not relieve a bank from its obligations to comply with antidiscrimination laws or regulations, such as the prohibition in the Equal Credit Opportunity Act against discrimination in any aspect of a credit transaction on the basis of race, color, religion, national origin, sex or marital status, age, or other prohibited classifications.

Oh boy - we can pick which regulation to violate!

Seriously, we are required to copy the photo ID but can't have it in the file. Are people setting up a separate file drawer to keep the ID copies by loan or application number? We need to retain the copies for five years after the account is closed so we could be looking at a 35 year storage potential.

In reply to:

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Oh boy - we can pick which regulation to violate!

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Neither Reg B nor ECOA states that a copy of a drivers license or other photo ID may not be in a loan file. The text quoted by Andy states that it is still unlawful to actually discriminate on a prohibited basis. The idea of keeping verification information separate is a good one but isn't required by law or regulation.

We do plan on keeping a separate file system for the ID (and hopefully imaging soon) with restricted access, so that eliminates the concern for curious, discriminating lender eyes. Kinda like Bette Davis eyes.