When can we use a scan of an ID?

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Question:

We are offering loans via a mobile app. Can we accept scans of IDs as that is a good way to help verify we are engaged with our customer, by having them send us a picture of their ID using a smartphone.

Answer:

Section 213 of the Economic Growth, Regulatory Relief, and Consumer Protection Act does allow a bank to meet CIP requirements by receiving a copy of a driver’s license or identification card to record the personal information of a person requesting to open an account or for some other service through the Internet. These are state issued licenses and ID’s, and the images cannot be retained or used for any other purpose than is allowed by this section.
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