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#94874 - 07/08/03 05:18 PM CIP - Documenting your ID verification
GreatBlue Offline
Diamond Poster
GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
This is probably something that has been asked and answered, but I can't find it.

How are you all going to document the the nondocumentary methods used, the results of each method used, and the resolution of any discrepancy?

Will you have a separate identity verification worksheet that becomes a permanent part of the customer file? I could see some of it being stored electronically in the CIF record, but I don't see how you can have a system that would fit every contingency.

What are your plans?

In giving this more thought, I have more questions...

There are several non-documentary methods where the presence of a document in the file could indicate that a particular method was used, and the document itself would show the results. For example, would keeping a copy of a credit report in the loan file be adequate documentation of the fact that the credit report was used for id verification and the results of that method, or must we separately indicate somewhere that a credit report was used for ID verification and that the results were acceptable?
Last edited by GreatBlue; 07/08/03 05:27 PM.
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#94875 - 07/08/03 05:23 PM Re: CIP - Documenting your ID verification
Anonymous
Unregistered

We are going to have an account worksheet where we will document the non-documentary methods we used along with any discrepancies and the resolutions of those discrepancies.
We have paper signature cards that are 81/2 by 11 we keep them in plastic sleeves. We will keep all the backup documents and worksheet with the signature card. Hopefully this will work!!!!!!!!!!

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#94876 - 07/08/03 06:18 PM Re: CIP - Documenting your ID verification
Nanwa Offline
Power Poster
Nanwa
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA

We use a New Account Reivew form, which the customer service rep fills out. This includes whether ChexSystems was run and if anything was found, ID/drivers license number, how account was opened (cash/out of town check/etc.), how long at address and job, and whether the address and job were verified by calling or checking in phone book. Then we scan these into optical so we have a permanent record. I shred (YES SHRED!) the hard copies after 6 months.
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#94877 - 07/08/03 08:58 PM Re: CIP - Documenting your ID verification
pgrimes Offline
Member
pgrimes
Joined: Jun 2002
Posts: 64
Glenview, IL
We're scanning everything into the customer file including copies of ids. We routinely use the credit report for all new account holders and have been scanning them all along anyway. If there is any exception being made, we are requiring a senior manager to approve the exception in writing and then scan that document to the file also.

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#94878 - 07/08/03 10:15 PM Re: CIP - Documenting your ID verification
Anonymous
Unregistered

p,

We are considering scanning. Which imaging product are you using? Do all your workstations have access?

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#94879 - 07/09/03 01:51 PM Re: CIP - Documenting your ID verification
pgrimes Offline
Member
pgrimes
Joined: Jun 2002
Posts: 64
Glenview, IL
We use Kirchman's Bankway system for both platform and tellers and will be scanning directly into their files. They just enhanced their system to allow this. The bankers will scan id at account opening. We are tossing around the idea of getting scanners for the tellers to scan existing customers ids but are holding out on that until the dust truly settles on this reg.
We scan documents through AFS's Imagevision system - I don't know for sure but I would think they have an id scanning product.

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#94880 - 07/09/03 01:57 PM Re: CIP - Documenting your ID verification
Anonymous
Unregistered

We have a "CIP Information Sheet" used for all departments covered. The reg requires you to list the non-doc methods so we have them listed as well as to which are required and which are other means to handle the issues. It also has text boxes for discepancies found, methods to resolve them and other comments.

I am writing a computer program to handle the form. We decided not to put these forms in any product's folder since they could get lost or misplaced. Also easier to review. The computer program has an exception process built in to flag the officer of accounts of errors or omissions.

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#94881 - 07/09/03 05:51 PM Re: CIP - Documenting your ID verification
Ms Auditor Offline
100 Club
Joined: Oct 2001
Posts: 148
Upstate NY
We plan on having a separate ID verification sheet that would indicate which method(s)we used to verify a customer, any discrepancies and our next steps. We think we are going to file these sheets in date order and then destroy them after 5 years. The reg only requires that info to be kept that long.

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#94882 - 07/09/03 07:42 PM Re: CIP - Documenting your ID verification
LiL Bit Moore Offline
Platinum Poster
LiL Bit Moore
Joined: Nov 2002
Posts: 624
Texas
Will you have something on your system that indicates the CIP has been performed and when? If not, if it is filed in date order vs in customer file or filed alphabetically, how will you avoid repeating the verification multiple times?
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#94883 - 07/09/03 07:58 PM Re: CIP - Documenting your ID verification
Anonymous
Unregistered

This bank has a lhigh volumn of mortgage loan activity. most of it will be non documentary because it is brought in through the web or phone applications. We just had a meeting and we would like to see something on the systems. Does anyone have any ideas of what I can put out there? I suggested a box noting the type of verification used. Others thought a drop down box. The concern is how will someone else know that we did what was required. However, since we all know how fast IT is this won't happen in time.

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#94884 - 07/09/03 08:16 PM Re: CIP - Documenting your ID verification
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
If you have completed the CIP requirements and opened an account for the new customer - the next time they come in for another product, they are no longer a new customer under CIP, and presumably are on your CRF records.

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#94885 - 07/10/03 06:20 PM Re: CIP - Documenting your ID verification
Miss Kitty Offline
Platinum Poster
Joined: Mar 2002
Posts: 721
California
Quote:

We have a "CIP Information Sheet" used for all departments covered. The reg requires you to list the non-doc methods so we have them listed as well as to which are required and which are other means to handle the issues. It also has text boxes for discepancies found, methods to resolve them and other comments.




Ben - would you mind sharing your form? We're going back and forth as to how to handle Op's & Lending.

Thank you.


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#94886 - 07/10/03 08:44 PM Re: CIP - Documenting your ID verification
vlg Offline
Member
vlg
Joined: May 2003
Posts: 74
Ben, If you are able to share your form I am also interested in receiving it. We looked to our vendors for support, but so far everything seems cumbersome. I expect we will design our own, so an idea from someone who has actual begun using it would be helpful. Thanks

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#94887 - 07/11/03 10:00 AM Re: CIP - Documenting your ID verification
Anonymous
Unregistered

I am only glad to share. One form handles both business and individual. Radio boxes distinguish one from the other.
The drop downs for documents can be customized since it is based on a ID database. So you will get two sheets back from me. Email ben.hicks@mercantile.net

I may eventually for contingency purposes (network down) make an Adobe Acrobat fill in form which can be distributed to individual PC's. You create a local data source which is then synced up with the network when the network comes back up.

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