USA PATRIOT Act: ID Requirements For A Minor

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Question:

Our credit union has a location in a high school. I didn't see in the US Patriot Act where it addresses what ID is required for a minor. We allow 16 year olds to have an account without a parent. What if they have a single party account but does not have a valid state ID only a student ID?

Answer:

Based on the proposed regulations, your Member Identification Program will establish its own standards for what you require to verify identity. For example, you may generally require "Two pieces of documentary verification, one of which must be "primary" identification (government issued with photograph)".

If you wish to create specific exceptions for people who do not have photo identification; e.g., the elderly, the disabled or minors, you will spell them out in your board adopted policy. For example, it might say: "For individuals under the age of 18 who do not have photo identification, we accept a birth certificate and a Social Security card in lieu of photo identification."

Alternatively, if the high school where you have an office has student IDs, you may indicate they are acceptable as primary identification for persons under 18.

Anytime you create exceptions, you are allowed/required to consider the risks involved.

First published on BankersOnline.com 11/18/2002