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FDIC Federal Register Citations

From: Jennifer Filling
Sent: Thursday, September 05, 2002 4:52 PM
To: Comments

Subject: Customer Identification Program Comment

Section 326 of the USA PATRIOT Act (103.121(b)(3) Recordkeeping) requires the bank to maintain a copy of the document relied upon that evidences the type of document and any identifying information it may contain.

1. Our question is will a notarized copy of the document used to identify the customer be sufficient for recordkeeping purposes? The example would be if a joint account is opened for a mother and daughter. The mother lives here but the daughter lives out of state. Can the daughter have a copy of her identification notarized verifying her identity?

2. For minor (custodial) accounts will the social security number need to be verified? and or birth certificate?

Thank You,
Jennifer Filling
AVP-Retail Banking Compliance Officer
1st Mariner Bank
1516 S. Baylis Street
Baltimore, MD 21224
410 342-2600 ext:3346

 

Last Updated 09/06/2002 regs@fdic.gov

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