Though the credit union may retain a copy of the ID, it certainly is not required. So, a description is generally sufficient. Generally, the rule requires a credit union to retain a description of the document that was relied on, noting the type of document, any identification number contained in the document, the place and date of issuance, and expiration date.
CASH A CHECK WITH A PHOTOCOPY OF ID VERIFICATION
But should a credit union keep a copy of the ID in its records? For recordkeeping purposes, the CIP rule leaves it up to the credit union to determine how it wants to document verification that has been performed. So collecting the ID to verify the information is one thing. This includes checking a government identification number, which can be done with documentary evidence like an ID. The Bank Secrecy Act requires a credit union to know its member (KYC or KYM whichever lingo you prefer) and have a customer identification program (CIP). Contrary to what we've been taught, what's good for the goose is NOT always good for the gander. However, it got me thinking about compliance issues relating to IDs, such as military IDs and fair lending concerns. Yes, the copy of the ID is great for verifying your members' identity or helping to detect fraud. While I understood the benefits of having the copy on file, I could not help but to think about the different compliance issues this raises. The teller said she would be able to process my request only if the credit union had a copy of my ID on file. I told her that I did not have any ID on me (don't judge me!), but I had my ATM/debit card. The teller asked me for my driver's license or any similar ID. I decided to walk into the branch and ask for the cash withdrawal. So last week, I attempted to take some cash out of my credit union's ATM but the customer in front of me had a bunch of checks she had to deposit and took forever. Written by Shereefat Balogun, Regulatory Compliance Counsel
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