03/03/2003
After writing a CIP policy (not yet approved by the BOD) only to have the final rules postponed, we decided to take a wait and see position before copying the drivers license for new accounts or putting any of our other requirements in place. Are we okay with this, or are we out of compliance?
02/03/2003
I understand that it is not a violation of ECOA to require an ID and photocopy it at loan closing. However, also I understood that taking a photocopy of a picture ID for a loan file is considered "collecting monitoring information" which according to Section 202.13 of Reg B is allowed only for credit secured by a dwelling. Aren't we setting ourselves up for "discrimination in lending" by keeping pictures of those we approve and decline in loan files?
01/06/2003
There are many new sofware products being offered today to assist in 'verfifying' the identity of new and/or existing bank customers (per proposed rules of the USA Patriot Act). These software packages search a number of various databases to get background and other 'verification' data. Some of the data bases that are 'searched' appear to be readily accessible general public record data bases, but others appear to be data bases that are not so accesssible by the general public. Is it permissible to have a customer sign a form which essentially says that the customer agrees that the bank can search for information to verify the customer's identity without specifically identifying the data bases being searched?
01/01/2003
2003 was one crazy year!
It?s time to reflect as 2004 draws near.
Remember that Orange Terror alert?
Some still have duct tape stuck to their shirt.
12/02/2002
In regard to the proposed CIP rules, how do we handle an existing customer who refuses to provide photo ID when opening a new account? We know the customer because we have dealt with him/her for years.
12/02/2002
We are updating our Safe Deposit policy to reflect the USA PATRIOT Act. I would like to know what you think the procedures for a deputy should be as far as verification of the identification. Should we treat a deputy the same way we would handle adding a signature to an account?
12/01/2002
The US Customs Service has implemented Operation Green Quest.
12/01/2002
The pressure is off, thanks to FinCEN's announced delayed effective date, but you'll still have to develop a customer identification program. Now you have the time to do it carefully.
12/01/2002
Customer Information, a.k.a Know Your Customer, has been at the core of what we call dueling regulations.
11/18/2002
Will we need to obtain a copy of a driver license for a guarantor on a loan?