Skip to content

Can I copy an ID?

Answered by: 

Question: 
Ever since CIP we started keeping copies of IDs in our files. Is this OK?
Answer: 

Reg B and fair lending laws do not prohibit this. But a few cautionary points must be made. CIP doesn’t require keeping copies, but doesn’t prohibit it. A copy of an ID is not unnecessary collection of monitoring information, but it could be used against you. Reg B prohibits discrimination on a prohibited basis at any time during the transaction. Banks test for fair lending when loans are made, but loan collections count too. Having the ID copies separated from a loan file help insulate a collector from a claim that they treat customers differently based on race or sex, as examples. And lastly, military IDs should not be copied and retained in your files.

-----------------------------

Learn more about Andy Zavoina’s webinar A-Z of Reg B

First published on 07/26/2020

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics