Answer:
Reg B and fair lending laws do not prohibit this. But a few cautionary points must be made. CIP doesn’t require keeping copies, but doesn’t prohibit it. A copy of an ID is not unnecessary collection of monitoring information, but it could be used against you. Reg B prohibits discrimination on a prohibited basis at any time during the transaction. Banks test for fair lending when loans are made, but loan collections count too. Having the ID copies separated from a loan file help insulate a collector from a claim that they treat customers differently based on race or sex, as examples. And lastly, military IDs should not be copied and retained in your files.
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Learn more about Andy Zavoina’s webinar A-Z of Reg B
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