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FDIC Federal Register Citations |
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Gentlemen: Franklin Savings Bank has maintained a Know Your Customer Policy for several years. We verify the identity of accountholders using various methods, both documentary and non-documentary. At present, we record information from documentary evidence both on signature cards and online in our Customer Information Files, but do not retain a hard copy on the majority of customers. Hard copies are retained only on those who attempt to open an account other than in person. Our records contain the type of documents presented, issuing agencies, and identifying numbers. Section 103.121(b)(3) of 12 CFR Part 326 addresses proposed recordkeeping requirements of the USA PATRIOT Act. As proposed, we would be required to maintain a hard copy of all documentary evidence used and also keep a manual record of efforts to verify identity through non-documentary means, as well as the results of those efforts. The additional recording would be burdensome both in terms of time and space, especially considering the retention period of five years after account closing. It would not be so if the regulation allowed us to continue recording the information in lieu of making and keeping an actual photocopy. That way, the information is on the signature card permanently, even after an account is closed. The information would also be readily retrievable. Thank you for your consideration of my request. Judi Greco Senior Vice President Customer Services |
| Last Updated 08/01/2002 | regs@fdic.gov |