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ID Verification Via Mail for HSAs

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Many financial institutions that offer health savings accounts (HSA) simply request that the HSA application with initial deposit, and only a copy of an ID as verification be mailed, not presented in-person. With numerous HSA's being established out of state, no in-person verification is requested and seems to conflict with the PATRIOT ACT’s customer profile information requirement. How can our bank open HSA’s and not have the customer do this in-person, can this be done strictly via mail?

Under the CIP (section 326), financial institutions are required to obtain four main pieces of information from the customer (name, address, identification number, and date of birth) prior to opening the account. Additionally, institutions are required to validate this information via documentary or non-documentary methods or both. In order to deal with a “face-less” environment, several banks have implemented non-documentary procedures to verify the customer’s identity without requiring them to come into a branch.

Running credit reports (e.g. TransUnion or Equifax) has become a popular method to verify that the customers name, social security number, date of birth and address match the information provided on the application. Additionally, there are vendors that allow institutions to ask “Out of Wallet” questions. These types of questions would be difficult for an identity thief to answer if they found someone’s wallet or purse. Examples of these multiple choice questions include: What is your monthly mortgage payment? or Which institution finances your vehicle? If an individual is unable to answer the questions correctly, the bank would receive notification that the account was not opened and could investigate the possible suspicious activity.

Banks can also add an additional layer of protect by requiring all new applications to include a copy of their ID (documentary method). This would provide the institutions another method to ensure the customers information matches. Many times these IDs are difficult to read because of black and white copy machines - which is why having a strong non-documentary process is so important.

First published on 9/18/06

First published on 09/18/2006

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