We've been having a conversation with the security officer about information that is obtained during the account opening process and are a little concerned. The SO has been training the tellers to collect race and sex information as follows:

Recording ID Information


Anytime a teller or CSR accepts any identification to open an account or when a customer receives cash back from a transaction, the following information needs to be recorded:


Type of identification
Individuals race B-Black, W-White, H-Hispanic, O-Other
Individuals sex M-Male, F-Female
Identification number – preferably the social security number *
Date of Birth or DOB

He tells us that he has been doing this for quite some time and has gotten legal's approval, etc. We've talked with legal and they are not so sure that they did agree with this. But before we react, just want to check with some of the BOL security folks to see if this is standard industry practice. Thank you for your thoughts.

Why would you go through all of that documentation. If you have a valid driver's license presented and the teller looks at it and actually compares the person in front of them to the picture ID, what more do you need than the DL #? If something goes wrong with the transaction, you will be able to get all that information from the DL records. If the DL is fake - what good will the information do you? You should have them on camera anyway. Bad practice - waste of time.

I agree...what is his reason for doing all that?

rl makes some great points...

Here's what I have from the Security Officer:

"When item is returned and becomes a case, one of the first thing the investigators do is review surveillance coverage and attempt to "properly" identify the individual that presented the item. Investigators are not suppose to make assumptions so they depend on the information provided by the tellers so that they may identify the correct individual. We do not want to error in identifying possible suspects so being accurate is critical. With names like Jon,Francis, Leslie, Sonny and others we can not assume that they are male or female and for these same reasons we also can not assume their race.

As a side note: We are not aware of any customer complaints on this issue since we started printing this information on the check as opposed to hand writing this information on the back of the check."

Why isn't your time on your teller machines synchronized with your time on the camera's. If you can't prove that (i.e., by freeze framing the video when the teller receipts the check in the teller machine and having the time match on the receipt and video)a notation on the check is worthless. It could be any other transaction you have filmed. Lousy excuse for a total waste of time and inconvenience of the customer if you ask me. It's all there already if he just cares to take the time to look. Unless you make a habit of cashing bad checks - how many time has this information actually (not theoretically) assisted in a recovery where you couldn't have found the information through other methods? I would bet you it is few and far between.

Not aware of customer complaints - you bet you aren't. If you read the latest studies you will find that most banking customers vote with their feet on such issues. I know I would the first time you noted my race on the back of a check I was cashing.

Thank you for sharing your thoughts, these are good points and we are in agreement just wish we could get the SO to see it that way. Another concern that we have is whether we may have Reg B concerns on him collecting this information (race/sex) when it is not required. This would be done mainly for opening a deposit account account but if the information is recorded and retained and the customer applies for a loan (non-HMDA, not Reg B) could we have a problem? If this question needs to be directed to another forum, I'll be glad to repost. Thank you.

Please explain this:

"since we started printing this information on the check as opposed to hand writing this information on the back of the check"

I believe you could have a real legal problem on your hands collecting this information. If a customer charges you with discrimination and it comes out in court that you have all of this information on your deposit customers, your bank will look very foolish. This type of information being available puts the bank in a defensive mode whenever it comes up, whether a non-real estate related loan, or any other situation. You would have to show that the lender didn't have access to scanned checks, didn't use this info for any discriminatory purpose, etc.

Just because there are no laws that say you can't have this info on a deposit account doesn't make it okay. There are laws against any business discriminating against customers. This puts you immediately on the defensive. You need to have a long conversation with your legal department and really think this through. I wouldn't give up until it stopped if it were my bank. It is a no win situation.

Quote:

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....see if this is standard industry practice.

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It, very definitely, is not.

Our legal counsel has asked us to give them some feedback on why this would not be appropriate and have specifically asked if we could comment on Reg B. I'm concerned it's going to turn into a battle of wills (the SO's vs. ours) unless I can find something specific to direct him that states he should not be doing this.

The definition of "credit" for Reg B is very broad. Do any of these accounts have overdraft lines of credit?