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#620545 - 10/02/06 06:53 PM CIP and copies of the ID docs
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
So, three years later are you or are you not making copies of the ID docs. to prove that you have obtained the ID (or that your account opening staff actually saw the ID)....this goes back to a recent chat with our BSA examiner...who was looking for the proof (document).....supporting the ID info on our database.

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BSA/AML/CIP/OFAC Forum
#620546 - 10/02/06 06:52 PM Re: CIP and copies of the ID docs
mck401 Offline
Diamond Poster
Joined: May 2006
Posts: 1,168
Texas
At my current bank, yes we make copies of ID for CIP purposes for new accounts. On the loan side, we document the information when we are closing the loan. We are a small community bank and 'know' most of our customers however our board wanted a conservative approach and so it's in our procedures. My previous bank was much, much larger and we did not make copies of ID. Each new account person recorded the information including expiration date, and the information was entered into our database.
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#620547 - 10/02/06 07:06 PM Re: CIP and copies of the ID docs
dare2dream Offline
100 Club
dare2dream
Joined: May 2005
Posts: 128
California
we are similar to mck401's previous bank. We simply obtain the information and ensure that it's on the sig card and on the system. We do not keep copies of the documents presented at time of account opening.
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#620548 - 10/02/06 07:09 PM Re: CIP and copies of the ID docs
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,238
New York City
As a small community bank, we are making copies of the ID. The only exception is if a customer really objects to it, then we would document all of the required info. and what type of document( for example, a drivers license) we obtained it from. I have one concern in these situations. Isn't a customer refusing to let us copy their ID a red flag to begin with?
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#620549 - 10/02/06 08:08 PM Re: CIP and copies of the ID docs
Bank Angler Offline
Gold Star
Bank Angler
Joined: Apr 2004
Posts: 461
Just a short drive from Lake E...
We keep copies, but got criticized on our exam if the info on the driver's license didn't match up exactly to the info collected for CIP purposes. Our examiner said that if the the verification document didn't match up exactly, we either needed a narritive to accept it or another verification document. We are working on new procedures.
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#620550 - 10/02/06 08:37 PM Re: CIP and copies of the ID docs
FlBankerGal Offline
Member
FlBankerGal
Joined: May 2002
Posts: 91
We too keep copies in our DDA files. And yes, examiners did find some typo's but not so many since it got no mentioned in the final results.

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#620551 - 10/02/06 08:34 PM Re: CIP and copies of the ID docs
waldensouth Offline
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waldensouth
Joined: Nov 2001
Posts: 7,981
FINALLY ABOVE the gnat line
We obtain copies of the ID documents but only for 2nd review/audit purposes. The CSR is responsible for obtaining the info and loading it into our system. someone back office verifies that the info is correct next day - they verify it against the copies. The copies are then shredded. We don't retain them forever.
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#620552 - 10/02/06 08:56 PM Re: CIP and copies of the ID docs
BSA4LIFE Offline
Gold Star
Joined: Nov 2003
Posts: 284
California
We do not keep copies, the next day a second employee must verify that the information has been entered on the system, but they have no source documents to verify that what has been entered is correct. I feel that we are not doing a sufficient verification this way, but so far we have not been criticized.

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#620553 - 10/03/06 01:20 AM Re: CIP and copies of the ID docs
Banker Boy Offline
Member
Banker Boy
Joined: Oct 2003
Posts: 69
Florida
We keep copies (or are supposed to). Too often we're not able to locate a copy of ID which is listed on the system. It's not a centralized system so each branch keeps their own copies.

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#620554 - 10/03/06 01:42 PM Re: CIP and copies of the ID docs
Auditman Offline
100 Club
Joined: Nov 2004
Posts: 132
Our community bank's CIP requires that we record the information, but does not require that a copy of the document be kept.

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#620555 - 10/03/06 03:16 PM Re: CIP and copies of the ID docs
Trees Offline
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Joined: Apr 2005
Posts: 4,013
For those of you who had their recent BSA exam (i.e. in 2006) was the fact that you did not have copies of source documents ever made an issue?

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#620556 - 10/03/06 03:33 PM Re: CIP and copies of the ID docs
Bank Angler Offline
Gold Star
Bank Angler
Joined: Apr 2004
Posts: 461
Just a short drive from Lake E...
Trees, our examiner criticized us because we did not document any differences in the collected information and the verification document. For example, she pulled an auto loan that was done for one of our employees just after she was married. The application had her married name on it, but her driver's license had her maiden name. The examiner said that we couldn't use the driver's license as a verification document unless we documented the difference and how we cleared up the name difference.
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#620557 - 10/03/06 05:40 PM Re: CIP and copies of the ID docs
Auditman Offline
100 Club
Joined: Nov 2004
Posts: 132
We had a recent OCC exam in 2006 and the fact that we did not have copies of source documents was not made an issue.

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#620558 - 10/03/06 06:08 PM Re: CIP and copies of the ID docs
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
If an examiner ever criticizes not having copies of ID documents, just refer then to the BSA Exam Manual. It's very clearly stated that the CIP regulation doesn't require copies. If your CIP policy requires it, however, you would have to abide by your policy unless and until it gets changed.

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