Can a bank keep copies of documents provided to verify a customers identity, in addition to the description required under 31 C.F.R. 103.121(b)(3)(i)(B), even if it is not required to do so?
Yes, a bank may keep copies of identifying documents that it uses to verify a customers identity. A banks verification procedures should be risk-based and, in certain situations, keeping copies of identifying documents may be warranted. In addition, a bank may have procedures to keep copies of documents for other purposes, for example, to facilitate investigating potential fraud. (These documents should be retained in accordance with the general recordkeeping requirements in 31 C.F.R. 103.38.) Nonetheless, a bank should be mindful that it must not improperly use any document containing a picture of an individual, such as a drivers license, in connection with any aspect of a credit transaction. (January 2004) 31 C.F.R. 103.121(b)(3)(ii) Retention of records 1. Does the original information obtained during account opening have to be retained or can the bank satisfy the recordkeeping requirement by just keeping updated information about the customer, i.e., the customers current address? T
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- Can a bank keep copies of documents provided to verify a customers identity, in addition to the description required under 31 C.F.R. 103.121(b)(3)(i)(B), even if it is not required to do so?
- Can a bank use an employee identification card as the sole means to verify a customers identity?
