Record Retention Period for an ID Image

Posted By: hsbs

Record Retention Period for an ID Image - 09/25/20 09:31 PM

Hello,

Is there a regulatory retention period for an ID image for an online opened account? To rephrase it... if one of our customers opens a consumer account online (checking/savings account), and they provide us with a copy of their ID... is there a record retention period for the copy of the ID that is required by any regulation/rule?

Thank you all for your help.
Posted By: rlcarey

Re: Record Retention Period for an ID Image - 09/25/20 09:37 PM

If they provided it during an online opening process, then it has to be deleted after the account is opened per S. 2155
Posted By: hsbs

Re: Record Retention Period for an ID Image - 09/25/20 10:12 PM

Thank you very much, Randy.
Posted By: DBouton

Re: Record Retention Period for an ID Image - 11/12/20 09:05 PM

Randy

Does this apply only to credit unions?
Does this apply only to online account opening?
Posted By: BrianC

Re: Record Retention Period for an ID Image - 11/12/20 09:34 PM

Quote
Does this apply only to credit unions?


S. 2155 Sec 213(a)(4)

(4) Financial institution.--The term ``financial
institution'' means--
(A) an insured depository institution;
(B) an insured credit union; or
(C) any affiliate of an insured depository


Quote
Does this apply only to online account opening?


S. 2155 Sec 213 (b)
.--When an individual initiates a request
through an online service to open an account with a financial
institution or obtain a financial product or service from a
financial institution,
the financial institution may record
personal information from a scan of the driver's license or
personal identification card of the individual, or make a copy
or receive an image of the driver's license or personal
identification card of the individual, and store or retain such
information in any electronic format for the purposes described
in paragraph (2).
Posted By: rlcarey

Re: Record Retention Period for an ID Image - 11/12/20 09:35 PM

Refer to Section 213

https://www.congress.gov/bill/115th-congress/senate-bill/2155/text

It applies to all financial institutions and this is all we have at the moment. There has been no additional regulatory guidance issued.
Posted By: Joybell

Re: Record Retention Period for an ID Image - 11/13/20 09:23 PM

Is this in effect now? If so when did it go into effect?

Thank you
Posted By: rlcarey

Re: Record Retention Period for an ID Image - 11/13/20 09:42 PM

There is no effective date in the legislation so presumably it was effective the day the Act was signed.