Answer:
I suggest you go back and read the CIP regulations at Section 103.121(b)(1)(ii) of 31 CFR Part 103 carefully. If your bank’s CIP allows it, you can verify identity using other methods besides examining documents such as those you've described.
If you don't want to turn this group of customers away, your bank should amend its CIP to add provisions for alternative methods of verifying identity under circumstances such as this. Work with staff in your bank who are familiar with this customer base to identify ways the bank can verify identity to its satisfaction. Enlist assistance from leaders of the Amish community to help you understand the methods you may be able to rely on. Then enable the use of those methods by accommodating them in your CIP and ID verification procedures.
First published on BankersOnline.com 2/14/11
print
share