I need some advice. At my previous bank, we completed a customer information sheet that the lender signed to the verification of the information provided by the borrower(s)of their identification. The lender would then provide a copy of the printout from the Patriot Act website to the verification of the information. This was all that was required. I have now started at a smaller and newer bank. The requirements here are the same but for a additional Patriot Act Disclosure form that is signed by the borrower(s) stating they understand why we are pulling the information. Is this a requirement to have the form signed by the borrower(s) or is the one completed by the lender and the printout of the patriot act verification sufficient enough for the files. Any response is greatly appreciated!

What exactly is a Patriot Act Disclosure form? It does not sound like any disclosure required under the regulations.

The name of the form states "Patriot Act Information Disclosure" Important Information About Application Procedures

Verbiage in the body states:
"To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies every customer. What this means for you: When you apply for a loan, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents."

I/we acknowledge that I/we received a copy of this disclosure.

The applicant(s) then sign the form.

This information is worded a little different but pretty much the same on the form that the lenders sign. Hope that helps. Thanks!

As long as your procedures call for this disclosure to be handed to the customer or you have these signs posted prominently in the branches, there are no customer signature requirements for this disclosure.

Thanks for your help!

Actually, the disclosure can be read to the customer, too. There simply is no format requirement. But if you don't have at least a visible notice posted or with your application package, you'll have a hard time documenting that you've taken care of the disclosure.

That makes sense! Thanks for the words of wisdom! I greatly appreciate it!

Isn't this simply the CIP Customer Notice, which can be done either in writting, verbally, or simply by posting sinage anywhere that an account is being opened.

Yes.

http://www.bankersonline.com/tools/operational/ciplobby.html

And requiring a signature and retention is an unnecessary burden.

Just a suggestion, Because not all loan aps are obtained face-to face or on-site - we include the CIP language in the beginning body of the ap.

And banks which take accounts, or allow accounts to be initiated, over the internet often post it on their websites as well.

Follow-up question to this very old thread -- however can accounts being opened online meet the requirements for the CIP / Patriot Act Notice if it the copy of the notice is behind a link titled "Patriot Act Notice" listed on the application before or does the full body text of the notice need to be displayed?

We display the full body of text with the rest of our disclosures for online accounts.