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FDIC Federal Register Citations

From: John Kalas
Sent: Wednesday, September 25, 2002 5:00 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments

Subject: Patriot Act [Billing Code: 4810-02] - Michigan Law

Bank regulators,

Recently, a state law in Michigan was amended to make it a crime to possess reproduced or duplicated driver's licenses--Section 257.310(9) & (10) of the Michigan Statutes, apparently Public Acts 126 and 127 of 2002. This law becomes effective October 1.

This will create problems for bankers who plan to comply with the Patriot Act verification requirements by retaining copies drivers licenses.

Also, take the opportunity to clarify that the simple act of retaining a drivers license for verification purposes under the Patriot Act; does not raise an issue under the ECOA. Examiners over the years have scared banks with this issue; and it was recently repeated at a fair lending conference.

Johnny Banker

Last Updated 09/26/2002 regs@fdic.gov

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