I just viewed some software that I would like to share with others that are trying to come up with solutions to accomodate the USA Patriot Act dealing with identifying the customer and maintaining the identification used. I am not gaining anything from this note nor am I selling the product, just wanted to share. The software is from CD Solutions, Inc. telephone Doug Deese at (205) 223-2629. The software will allow new account reps and loan officers to scan the item used for identification, such as driver's license. The software does work in conjunction with Jack Henry System, so it pulls the customer's data base with the identification and stores it on imaging. One extra feature is that the tellers can use the image of the id to verify customer's cashing checks, etc. which may help cut down on identity theft and fraud. Also a field could be noted on the Jack Henry System that the id was obtained so bank employees are not trying to get the id copied more than once from each customer. I was very impressed with the product and just thought others may want to view it. Hope this helps.

Opinions are mine, not my employer, and this is in no way an advertisement or endorsement of the product listed.

We have just "heard" where the state DMV said that photocopying licenses was OK, but imaging was not. We have yet to see that on paper....

What state are you referring to??
and what is the diffrent between a copy and an image??

just curious

I assume Chris is referring to NH since that appears to be where he/she? is from. I could be wrong.

I was thinking that VA and one other state didn't allow photocopies. I wouldn't have thought the two were have been distinguished, but a digitized version is more susceptible to being manipulated and used wrongfully.

It is my understanding that the regulation requires the documentation to be in a searchable data base. It would only make sense that they would permit imaging, although I am aware that this has not been specified as of yet. The software I viewed does the data base on imaging, but as a worst case scenerio, it would also permit scanning and printing in "hard" form without the imaging. But I would think this would be more difficult to retrieve.

One more note: the software also has safeguards against who can print, who can view, system access, etc.

Please share your information if you hear more or learn of other methods to maintain compliance with the Act.

Opinions and requests are mine not my employer.

Thanks for your help.

Where can I find information on photocoping of a Texas DL?

The last anonymous was by me (Maria). I forgot to log in first. sorry!!!

I couldn't find where 103.121(b)(3) required a searchable database. Am I blind and if so, help!

Well, I found it.. it was just passed and is effective Jan 2003.

(New Hampshire RSA)
242:1 New Paragraph; Drivers' Licenses; Prohibitions; Unauthorized Use of Personal Information. Amend RSA 263:12 by inserting after paragraph IX the following new paragraph:

X. Knowingly scan, record, retain, or store, in any electronic form or format, personal information, as defined in RSA 260:14, obtained from any license, unless authorized by the department. Nothing in this paragraph shall prohibit a person from transferring, in non-electronic form or format, personal information contained on the face of a license to another person, provided that the consent of the license holder is obtained if the transfer is not to a law enforcement agency. Notwithstanding any other provision of law, any person selling alcohol or tobacco who uses due diligence in checking identification to prevent unauthorized sales and purchases of alcohol and tobacco shall not be held responsible for the acceptance of fraudulent identification. Where due diligence is exercised on the part of the seller, the unauthorized purchaser shall be liable for any penalty or fine resulting from the unauthorized sale.

Hmmm - don't photocopiers scan, retain images electronically? (the new ones, for a little bit) I'm sure they won't go THAT far!

There is no prohibition against this. The AG has recently opined however, that banks cannot read the mag stripe data on the license to verify that it matches the DL. I think this is wrong and noted so in my CIP comment letter. The AG allows it for governmental purposes. What is this? So if the final reg will make it clear (yea, right) that this is a governmental purpose maybe we'll get a change.

cfinch - I did a quick search and couldn't find anything that addresses photocopying a driver's license in Texas. For those of you in the other states, you may want to make sure that something like that is actually codified and not just something that people have believed to be true for years (You know how those things go!)

North Carolina is the other state that prohibits photocopies.

I was thinking it was but I wasn't sure. Other than VA and NC, I am not aware of any. But I haven't thoroughly researched this either.

According to the ABA's CIP comment letter, these are the only two.

Getting back to your software, Maria - does it require a scanner at each station? Perhaps a handheld model? We photocopy most things and then use the Silhouette imaging system (JHA). We have full-time "scanners" with a hefty supply of eyedrops. Does it also require a separate module for the operating system?

You know, for about 50 bucks, you can go to your local Staples, Office Max, Office Depot, Best Buy, Walmart, or whatever, and get a Low Res digital camera.

You can take a photo of the DL on the digital camera, and store the image on your network or on a C.D. or whatever. You can put a "watermark" on your image file so that any reprints will have the mark on it along the lines of "BANK CIP USE ONLY."

The State DMV's would have to get whipped into shape on this. Perhaps ABA and/or the state bank associations could work out a compromise on the issue.

No it does not require a scanner at each location. I am sure it would make the procedures easier, but we are only going to have two scanners, if this gets approved by management. We will have one in deposit ops and one in loan ops. Each new account rep or loan officer will copy the license or etc. and forward to the operations dept. This will also establish more control on the system since only the ops staff will have access to conduct various procedures. Others will have viewing capabilities only.

Other people may be able to come up with other ideas. This was just one that seemed to work with us and I just wanted to share it with others in case others did not have a plan yet.

I think this will prove one of the most beneficial things we can do as bankers to cut down on fraud, suspicious activity, etc., but it will also prove to be one of the more difficult things we have implemented and maintained. But to be honest, I am sincerely glad to do my part to help our country's financial system and to stop dishonest people from doing wrong, if it works. But I also believe all banks will need to maintain the same standard if it is going to work. This is just my opinion but I am kinda naive and not as knowledgable as most of you in compliance but I do my best.

I like these Graemlins. Who invented them? It gives me a laugh. Life as an auditor/compliance person is difficult so humor is well appreciated!

Opinions are mine not my employer.

We are not a JHA bank, but we scan, and have been doing so for several years. We have one flatbed scanner in each branch to accomplish this. Speedwise, it's not the best solution, as the flatbeds are a bit cumbersome and slow, but the end result is quite worthwhile. We looked into using business card scanners, but the problem is twofold with those devices:
1- A driver's license is too rigid to feed through the scanner
2- Passports don't fit
So we continue on with the flatbeds until a better solution presents itself, which I believe it will. (Yes, folks, that was a prediction )