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#2161728 - 01/24/18 07:30 PM Intensive Supervision Appearance Program - HELP
JennKK2 Online
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Joined: Nov 2006
Posts: 315
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we are not familiar with opening accounts for immigrants. we have an individual who has presented the ISAP card as 1 of 2 identifying documents. I have done a quick google of ISAP - do we open account? do we need other information or identifying documentation?

minnesota
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#2161729 - 01/24/18 07:39 PM Re: Intensive Supervision Appearance Program - HELP JennKK2
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
Only documents set forth in your Board approved CIP program are acceptable. What those might be are up to the bank. Since they have to be in the process of deportation, why you would choose to open the account is ???
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#2161733 - 01/24/18 08:05 PM Re: Intensive Supervision Appearance Program - HELP JennKK2
JennKK2 Online
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Joined: Nov 2006
Posts: 315
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rlcarey,
that was my interpretation of my google search that they were in the process of being deported, however the individual presented current MN Health ID card and Current work permit. no we have nothing in the CIP policy addressing immigrant account opening. management has decided to open account
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#2161747 - 01/24/18 09:00 PM Re: Intensive Supervision Appearance Program - HELP JennKK2
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Quote:
no we have nothing in the CIP policy


This is Randy's point. Does the Board approved CIP allow the use of a MN Insurance ID and a work permit as sufficient government issued photo identification to perform documentary verification? If it does, fine. If it does not, then we are not acting according to our own policy and procedure to form a reasonable belief that we have identified our customer and can/should be cited in an audit or exam if this account is reviewed.
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