AD wrote:

Where a bank relies on a document to verify identity, the bank must maintain a copy of the document the bank relied on that clearly evidences the type of document and identifying information it may contain.

The question is, are you going to require a drivers' license, passport, etc. from each individual who becomes a customer? The proposed rule doesn't require that you do so. The risk-based approach permitted under the proposed rule should allow banks to make decisions as to hwn such identification is required.

As an example, suppose a partnership formed by a bank for the purpose of holding trust assets in nominee name wanted to open a certificate of deposit in your bank. Would you need to get drivers' license copies for the bank trust dept. personnel who are the partners? I would suggest that you don't. The other bank, after all, has to have a CIP just like you do. The possibility of a money launderer or terrorist being a named partner in such a partnership is virtually nil. The proposed rule allows you to recognize that an account opened by another financial institution is low-risk and accept some appropriate verification (say, a certification from the other institution) that the identification is correct.

I had someone suggest to me this morning that we carve out existing customers into a separate low-risk category. I haven't totally accepted that yet, but the thought is intriguing.

Trans Union Credit does it - I believe it is $0.25 extra. But under the "Special Messages" section with the Hawk Alert, they add "OFAC Advisor Alert", and the findings.