08/04/2003
Our bank accepts funds via wire transfer from a broker who places the funds with the bank on behalf of public school districts. The bank opens CDs with the funds in the name of the school district. What documentation will satisfy customer identification requirements?
07/14/2003
Student loans are applied for at the college and sent to the state regents for approval. They are then sent to us to fund. We never see the applicant. The name, address, TIN and birth date are fields on the application. Any comments on the verification process? Banks are not permitted to perform credit checks. We do perform OFAC checks.
07/07/2003
07/07/2003
Is a passport the only acceptable ID when a person fills out a W8?
06/30/2003
I am reviewing the final reg for the CIP and making adjustments to the program and procedure we compiled several months ago. At the end of the discussion of Section 103.121(b)(2)(iii) for Lack of Verification, the final reg indicates "...a bank must comply with other applicable laws and regulations, such as the adverse action provisions under ECOA and FCRA, when determining not to open an account because it cannot establish a reasonable belief that it knows the true identity of the customer." ECOA and FCRA deal with credit products, and I do not see how the current notices apply to denial because you cannot establish someone's identity. Even if you mark "Other" the notice portion refers to credit and I believe it would confuse the applicant. Any thoughts on this?
06/23/2003
Prior to the issuance of the final ruling on the USA PATRIOT Act, Section 326, we had already planned to scan photo identity documents on new customers. Since this will not be required under the final regulations, will it be a violation of Reg. B to maintain scanned images of a customer's driver's license or other photo identification document?
06/23/2003
With regard to the new CIP regulations, will we have to include indirect auto loans in the ID verification process, or can we rely on the info furnished on the application to the original creditor? (aka the auto dealer.)
06/02/2003
Does a corporate fiduciary (trust Dept) need any form of ID under CIP for testamentary trusts that they are opening as trustee. example: Jane Smith dies leaving a will and names the bank as trustee of the trust for the benefit of her grandchildren.
06/02/2003
When opening an account for a new customer must the individual present his or her social security card or provide documentation to verify the SS#, as a result of the provisions of the USA PATRIOT Act? Is not providing the SS# along with proper ID enough? Many individuals don't have anything with the SS# on it or carry it with them. We don't want to turn prospective account holders away for not having their SS Card.
06/01/2003
The rules are out and the initial shock wave is over. No more excuses. It is time to get serious about building a Customer Identification Program.
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