In my bank, we have a Patriot Act form that our customer signs and then a loan officer/customer service rep completes the rest (with info obtained from a driver's license, passport, etc.). At the top of the form it explains to the customer about the Patriot Act and why we record certain information to open the account, etc.

One of our loan officers created his own form and requests the ID to fill it in but doesn't have the customer sign (nor does it reference the Patriot Act or anything about it).

Is there a regulation that refers to collecting such information and having the requirement to have a borrower sign off on it?

Thanks in advance!

Regardless of any regulatory requirement, why would this one loan officer be allowed to deviate from your internal CIP procedures? Violating your own CIP procedures in a BSA exam is as bad as violating the reg itself.

BTW, the ID, as you refer to them, must be informed of the Patriot Act identification requirements.

Thank you very much--I am going to look through my BSA info and see what I have.

Ooops, my mistake. I meant the loan officer requests the identification (the "ID") from the borrower and the loan officer records the information but the borrower never sees it or signs it.

There is no regulatory requirement for them to sign the form that you record the ID on, however if it is in your CIP policy to have them sign it, then it must be signed.