Matricular Consular Cards

I am the new BSA Officer for our bank. The old BSA Officer has always stated that we can't use Matricular Consular cards as a source of identification due seeing fake cards in the past. Does anyone use or not use these as a source of identification?

We do not accept them and we are located close to the Texas-Mexico border.

Twenty five years ago it might have been more of an issue, but today, I would say they are reliable as long as you know what they look like.

It still isn't very common that a Matricular Consular card will be permitted in CIP, but I've seen it done - and it can be done if your policy/risk assessment justify/permit it. That said, most banks I've talked with near the border (like Valley girl) still won't touch them, which says something to me.

Let's talk about what the U.S. Government is on record stating. While the 2003 FBI testimony to Congress, https://archives.fbi.gov/archives/news/testimony/consular-id-cards-in-a-post-9-11-world
might be dated, at the time it was a concern enough to talk to Congress about it. I admit, I don't know what has been done about it since. If anyone has any U.S. Government-issued guidance on reliability of this card, please let us know.

I still can't get past the official's concern about how did they get here in the first place without a passport.
Banks are caught between providing good customer service, and aiding and abetting illegal immigration. We, by nature are a giving country, who bend over backwards to help people out. Yet illegal immigration illegal.

Additionally, my research indicates that only three states allow their Notaries to accept these cards. IL, NV and possibly CA. which also says something, when that function is all about verifying true identity.

I'm sorry if I sound over-reactionary. My professional experience in past life has been; daily physical inspection by armed guards of Photo ID to be allowed access to the control room of a Nuclear Reactor (the N-Reactor), U.S. military Secret clearance, with access to armed security areas, and U.S. Federal Building access, also requiring physical inspection of photo ID.

Here is the process to obtain. Acceptance is purely up to you:

https://www.nilc.org/wp-content/uploads/2015/11/Basic-Facts-about-the-Matricula-Consular.pdf

Bumping this as my bank is exploring offering products through Bank On.... The topic of Consular IDs and Municipal IDs has presented itself. After reading this from a couple years ago, and my own internet research, is that bank's are very torn on this issue. Most don't accept it, and the ones that do, like US Bank, require a second ID to go with it.

Is that still the case?

Also, what about accepting Municipal IDs, those issues in places like NYC where local governments might issue IDs? Haven't found any resources on that. Our existing policy is state issued IDs, no mention of municipal IDs. Can't find much research on that.

I'm not keen on changing our CIP policy to just accommodate this new product. If someone is here legally, they will have a passport or state ID. NY State DMV doesn't even accept it, they want the actual Consular Birth record when applying for an ID.

As Randy previously noted. It remains a business decision.

Business decision to protect from fraud mostly? It seems to be allowed based on regulatory guidance, I'm shocked more banks don't use them. If it's in your CIP policy, do you expose yourself to any liability other than fraud and difficulty recovering assets if you choose to do so?

My previous employer accepted the cards a primary ID for years. We had honest, hardworking individuals who needed a checking account, so they didn't have to pay high fees at currency exchanges to cash their checks. We had minimal fraud issues on those accounts, but they also weren't profitable accounts because they would usually just have direct deposit followed by a cash withdrawal of most of the balance. We always made it a point to remind our examiners that we were providing services to an underbanked/unbanked part of our community when it came time for a CRA exam. Our perspective was that we are bankers, not ICE or DHS.

Where it became an issue is when one of these customers who used an ITIN to open their account decided to apply for a mortgage and gave us a W-2 with a social security number on it. Then we had a SAR for ID Theft.

"If it's in your CIP policy, do you expose yourself to any liability other than fraud and difficulty recovering assets if you choose to do so?"

We accept them and we have never had a comment or criticism from a BSA examiner about it. We only accept them from certain countries which we commonly see, and we consider them higher-risk, so require secondary ID.