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Imaged Copies of ID

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Question: 
We currently take copies of picture ID when opening new accounts and place the imaged document on our mainframe. We do not have paper files. The question came up whether there are any Reg B violations since this info is readily available to the lenders. We have been through several OCC exams and nothing has been said but now I wonder if there are any problems having this available. From what I see, it is no different than having a paper file with the ID in it but I wanted someone else's opinion.
Answer: 

This is perfectly acceptable. Refer to footnote #50 on page 49 of the FFIEC BSA/AML Exam Manual where it indicates a bank may keep photocopies of identifying documents.

First published on BankersOnline.com 1/08/07

First published on 01/08/2007

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