SS# and Drivers License for Non-Customer Checks?

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Question:

Is there any regulation that requires obtaining/retaining a copy of a social security number and drivers license for any and all checks cashed for a non-customer, whether it is an on-us check or a check from a non-customer to an existing bank customer? We do understand the need to pull OFAC on all transactions that involve a non-customer no matter the amount of the check. It is very time consuming to make copies of IDs and the checks. Are examiners going to the extreme? If we check identification, it seems that with the OFAC that should suffice. Are all banks required to do this now?

Answer:

There is absolutely no regulatory requirement that a bank obtain any particular form of identification when cashing checks for non-customers, except when a CTR is required. The forms of identification your bank requires for check cashing are mandated not by regulation but by policy and procedures of the bank.

In some states it is illegal to record an SSN as part of the identification process for check cashing. And while it is routine to require a photo ID, often a driver's license, and to record information from the ID, making a photocopy is decidedly less common.

First published on BankersOnline.com 12/5/11