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#398467 - 08/12/05 06:21 PM Re: ID in Loan File
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
More and more banks are beginning to image ID's for positive identification when I come in to the bank. For instance, I know of several that scan the DL. When the customer comes in the teller line, to the loan officers desk, etc. the bank types in the account # or name and up pops an image of the person's DL. This is a great deterrent to ID theft and good customer service.

Chew on this. How is this any different from having a copy of the DL in the loan file?
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Lending Compliance
#398468 - 08/12/05 06:39 PM Re: ID in Loan File
Anonymous
Unregistered

Good point David...however I think it is a bit different because the ID in the loan file is tied to a specific transaction whereas the scanned ID that comes up is tied to the customer as a whole (as in their entire relationship with the bank) and not an isolated instance. Just my thoughts.

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#398469 - 08/12/05 07:11 PM Re: ID in Loan File
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
But if I have a car loan with your bank and you have scanned in my DL, you have my picture (which includes my sex and you can tell my race/ethnicity ( - I'm being sarcastic).

How can you argue that a scanned ID is acceptable, but a copy of a DL is not.

As one Anon said on 8/10/05:
Quote:

There is not a fair lending issue with keeping a copy of the ID in the loan file. There is only a fair lending issue if the information contained on the ID is used to discriminate. Do you keep your lending staff blindfolded so they can't see the applicants? I didn't think so. So, why would having a photo of the borrower be any different than seeing them face-to-face?



I agree. In fact, I made a similar comment about having a bag over the head of all loan officers a few years ago.
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#398470 - 08/12/05 07:15 PM Re: ID in Loan File
Anonymous
Unregistered

I think we agree with you David...but the point is that not all examiners treat the issue the same way. Some don't have a problem with the ID in the loan file, while others have a serious problem with it. Until the examiners have a uniform opinion on this issue , we will continue to have this discussion.

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#398471 - 08/12/05 09:05 PM Re: ID in Loan File
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I can't argue with that. BTW, I don't suggest that banks have the ID in the loan files. I'm just trying to defend that it is not an ECOA violation.

I believe that ID's should be in a centralized place. This makes it easier for record retention and you don't have to risk having this discussion (like we have been having) with your examiners.
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#398472 - 08/15/05 03:39 PM Re: ID in Loan File
Dolly Nugent Offline
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Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
Steve,

For reasons I mentioned in my response. Discrimination can occur later.
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#398473 - 08/15/05 06:33 PM Re: ID in Loan File
HRH Okie Banker Offline
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Joined: Jan 2003
Posts: 3,070
Oklahoma
Just to add to the discussion, we do put the copy of the I.D. in the credit file, but we cut out the picture first. That way we have all the info, have evidence that we I.D. the customer, but no picture for possible future dicrimination.
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#398474 - 08/15/05 08:16 PM Re: ID in Loan File
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Quote:

Just to add to the discussion, we do put the copy of the I.D. in the credit file, but we cut out the picture first. That way we have all the info, have evidence that we I.D. the customer, but no picture for possible future discrimination.



I hesitate to ask, but found that I couldn't resist . . . I must know:

Are you serious or joking?
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David Dickinson
http://www.bankerscompliance.com

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#398475 - 08/15/05 08:25 PM Re: ID in Loan File
HRH Okie Banker Offline
Power Poster
Joined: Jan 2003
Posts: 3,070
Oklahoma
Serious.
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