Does a CU need to get a driver's license copy every time they do a loan for a member if they have obtained it in the past? Can they just get the Driver’s License number instead of copying Driver’s License? What's the rule under BSA?
We store our backup tapes in the same type of fireproof cabinet that we use for loan files. Does this provide adequate protection for our tapes?
Lucy Griffin explained to our Minnesota Bankers compliance group that we must not keep photo copies of picture IDs in loan files because of a possible Reg B violation. However, we also do this when we open new accounts (it could be helpful in cases of identity theft, or just so staff will recognize new customers). We also do it when we make a credit card cash advance for noncustomers, as we have experience identity theft there. Can we do this in nonloan situations and not run afoul of Reg B or other regs?