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Can I copy an ID?

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

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 A-Z of Reg B

First published on 07/11/2021

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