I have read past post on this topic and I know it is like beating a dead horse, but so may people have different views.

How are other banks documenting 2nd forms of ID? We as many others accept a credit card for 2nd ID, however it cannot be photocopied or recorded, so how do you verify that it was obtained? In addition if anyone can point me in the direction to where I can read about credit card privacy, all I have found has been for merchants and recording of sales.

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it cannot be photocopied or recorded

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You may want to test that belief. There are many here who feel that using a credit card as a form of identification may increase the possibility of identity theft or at least the possibililty that the bank may be accused as complicit if a customer's identity is stolen. However, I don't remember anyone demonstrating that copying the card or recording the information was illegal or prohibited under federal law.

To expand the point to your final request, there is no significant federal regulatory structure relating to the privacy of credit card information. There are bits & pieces here and there.

We accept credit cards for a second ID and had been only documenting the type and expiration date, but during a recent exam were told that this was not sufficient documentation and that we must record at least the last four digits of the number. We do not keep photo copies of any of the IDs - including primary. We document numbers, issue dates and expiration dates on our customer's CIS file. Hope that helps with the first part of your question.

The required record keeping for documents is at subsection (b)(3)(i)(B) of the CIP regulation. You do not have to keep copies of any document, you just need to record the following information:

"A description of any document that was relied on under paragraph (b)(2)(ii)(A) of this section noting the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date"

Ken is right and Ted has provided the citation. SBR even confirmed that his/her bank has been cited for not documenting the CC#. I just wanted to chime in to confirm that I, too, have seen this cited and advise banks that if you use a CC as verification, you must document the number. So far there doesn't seem to be any difference in views.

So, the real question I think you need to consider is: If you're worried about documenting the CC#, why except them as a form of ID? I know that if I were your customer, I wouldn't give you a CC.

IN thinking about your bank's documentation requirement, go to the real world side of things and ask yourself, "How many potential customers actually carry a second form of ID -- beyond the usual state-issued driver's license or ID card -- if we decide not to accept credit cards as ID documents?" I just looked in my wallet and found a AAA card, a health insurance membership card, my driver's license (I have three and a half years to look better for the next picture), a grocery store discount card, two credit cards and two debit cards. I do have a passport, but certainly don't carry it.

My point here is that if you decide not to accept credit/debit cards as second forms of documentary ID, what's left? And if my wallet is typical, how many potential customers would be turned away by a requirement that they present two forms of acceptable ID?

Thank you for your reference. It has been very helpfull. Sometimes I think we go overboard to make sure we comply, which also means we make things more complicated for ourselves.

I have a question along these same lines. Our policy states you must have 2 forms of identification when opening an account with one being Primary. In the primary list it includes picture ID and social security number/passport#/matricular, etc. Everyone knows you cannot open an account without a SS# so is that considered 2 forms of ID when you get both the SS# and a drivers license/passport? I argued until I was blue in the face with our internal auditor about this and we were still written up for not getting a form of secondary ID even though we had 2 Primary IDs. Any suggestions on how to handle this in the future?

You could accept a SS card as a secondary form of ID as long as your CIP policy specifically allows it.

I'm not certain I understand, but if you are saying that obtaining a TIN is the same as obtaining documentary evidence of identity, it is not. A SS card or a letter from the IRS awarding an EIN might servce as documentary verfication that the number is accurate, but the number itself is not a form of identification.

If you got the customer's driver's license and SS number, but no card, you got one form of identification.

Your CIP may need some revision. Even a SS card doesn't meet the general meaning of "primary" identification. Primary identification is generally described as being issued by the government, containing a photograph and being relatively difficult to obtain.

Thanks Ken. I inherited the Policy along with the job a couple of months ago and wanted to change the policy to reflect that a SS number is not a primary identification but was reluctant to rock the boat so soon after taking over. I believe it is time to revise the Policy and your logic has made it simple to explain.

dcarlsen: One thing: when you say "Everyone knows you cannot open an account without a SS#", that's not really the case.

Under the CIP regulations, you can open an account for a "US Person" with either a TIN or an application for a TIN. For non-US persons the regulations allow either a TIN, a passport number and country, an alien ID card number, or the number and country of issuance of any other government-issued document evidencing nationality or residence and having a photo or similar safeguard.

In addition to Ted's posting above, if you open an account for a non-resident with NO Tax ID #, a W-8BEN form must be completed stating permanent residence of the non-resident alien in their country of origin.