Primary ID - photo exception

Posted By: ABT

Primary ID - photo exception - 06/15/12 09:23 PM

Are there any financial institutions that allow in their CIP policy/procedures for an exception of a primary ID not to have a photo for religious reasons? If so, how is the exception worded?
Posted By: Gatorgirl

Re: Primary ID - photo exception - 06/15/12 09:26 PM

How would you determine the ID belonged to the person in front of you? I would be concerned accepting something without a photo. How would these folks get a drivers license or a passport - a picture is required.
Posted By: Elwood P. Dowd

Re: Primary ID - photo exception - 06/16/12 01:45 PM

There is no regulatory requirement or practical necessity for obtaining photo identification.

Banks use other methods to verify identity when they are opening accounts online. Banks in states with significant Amish populations also frequently create exceptions in their CIP for people who do not have photo identification based on their religious beliefs.

You may draft your own language based on the tack you intend to take. In some cases, banks require a birth record and a verbal verification from a known "elder" in the local religious community. In some, the religious community issues laminated cards that identify the holder as a member of the religious community. Note too that some states offer "photo exempt" identification.

Whatever flexibility you may choose to offer in the way of photo identification, you may not waive or dilute the requirement to obtain a U.S. TIN from a U.S. citizen opening an account.
Posted By: Kathleen O. Blanchard

Re: Primary ID - photo exception - 06/16/12 01:51 PM

I agree with Ken. A photo ID is not a requirement.

Just remember to reflect the process decided upon in the Bank's board approved customer identification program.