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#87361 - 06/11/03 05:21 PM ID Record formate for CIP
Anonymous
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I can't find anything on this issue in the archives. Records are to be maintained for 5 years for the CIP. Can this be by recording it on a signature card and /or in a loan file or must you place ID with numbers(D/L) on a syatem so you have immediate access to it?

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#87362 - 06/11/03 05:31 PM Re: ID Record formate for CIP
JacF Offline

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There's no requirement to record the id info in one place or another, as long as it's recorded. But personally, I prefer keeping it in the CIF online for several reasons:
1- As you mentioned, it's readily available.
2- It allows you to keep all of the customer's id info in one place, making documentation and record keeping easier.
3- It keeps your staff from gathering and recording redundant information.
Last edited by JacFSB; 06/12/03 02:27 AM.
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#87363 - 06/11/03 05:36 PM Re: ID Record formate for CIP
Retired DQ Offline
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Turnpike Exit 10
Bob,
We wanted to put all of the ID data in our system, but there wasn't enough room and the expiration date couldn't be recorded.
We image our signature cards so they are accessible by the next business day.
For our loans, we are making a form to be included with all app packages.

Unfortunately, this I am sure will lead to redundancy!
This is so much fun, I can't stand it!
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#87364 - 06/11/03 05:47 PM Re: ID Record formate for CIP
Ted Dreyer Offline
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BOB: Remember, there is more to the record keeping requirement than just document information. You also need to maintain the method and results of any nondocumentary verification that you do as well as record any substantive discrepancies in verification and how they were resolved.

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#87365 - 06/12/03 01:20 AM Re: ID Record formate for CIP
Anonymous
Unregistered

We plan to include, in our procedures, the full description of how we will verify ID through non-documentary methods. If we do this, can it be just in the procedure IF it is a consistent process? The other ID we will try to capture electronically and where copies are obtained with loan applications that we purchase we will scan/image them. Does this sound ok?

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#87366 - 06/12/03 02:31 AM Re: ID Record formate for CIP
JacF Offline

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In addition to how your nondocumentary verification will be completed, I strongly advise adding when to the procedures as well. And like Ted said, you have to record that the verification was completed. If the process is the same every time, I don't see the need to spell out the process in the verification.

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#87367 - 06/12/03 02:56 PM Re: ID Record formate for CIP
Elwood P. Dowd Offline
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Next to Harvey
Just to make this a trio rather than a duet, I want to agree with JacFSB and Ted. You cannot satisfy a specific record retention requirement with a general statement of what your verification procedures are.

If Ted opens an account, you must describe how you verified his identity. If JacFSB opens an account, you must describe how you verified his identity. If the method was identical, that's fine, but, the record is specific to the customer.
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#87368 - 06/13/03 12:42 AM Re: ID Record formate for CIP
Anonymous
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Based on stating how you verified ID for each account where are you recording this information and how? Signature cards are not big enought to document this and I guess checklists can be made for loans.

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#87369 - 06/13/03 02:39 AM Re: ID Record formate for CIP
JacF Offline

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If the process is always the same, it isn't necessary to detail said process on the individual record. Just note what process was followed for that customer.
For example:
In certain circumstances, we use a positive id service to perform nondocumentary verification. Or CIP procedures spell out when we use this service, and what information we verify through this service. So we create a "Verified by ABC Service" field in the CIF to note when this is done. The person completing the inquiry simply inputs the date in the field (assuming the verification comes back ok.) This could also be easily done with a signature card template.

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#87370 - 06/13/03 02:42 PM Re: ID Record formate for CIP
Starky Offline
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Arkansas
Quote:

Based on stating how you verified ID for each account where are you recording this information and how? Signature cards are not big enought to document this and I guess checklists can be made for loans.




I don't what deposit forms you are using, but our Bankers Systems rep said they will include the information on their forms.

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