FDIC Federal Register Citations

Executive Secretary
Attention: Comments/OES
Federal Deposit Insurance Corporation

 Comments on Proposed Rules: Customer Identification Programs

FDIC, 12 CFR 326

To Whom It May Concern:

With regard to the proposed rules, I would like to offer the following comments and questions.

We currently verify the identity of account holders using both documentary and non-documentary methods. Currently, we record the information from and source of documentary evidence on the signature card, but do not retain a hard copy of the identification document for most of our customers. To maintain a hard copy of the documentary evidence would be burdensome in terms of time and space, and not necessary considering this information is already documented on the signature card.

The proposed rules state that a bank need not verify the identifying information of an existing customer seeking to open a new account, or who becomes a signatory on an account, if the bank (1) previously verified the customer’s identity in accordance with procedures consistent with the regulation, and (2) continues to have a reasonable belief that it knows the true identity of the customer. Would the documentation of identifying information and source for an established customer (as mentioned in the above paragraph) be sufficient or, in light of the proposed record keeping requirements, would we be required to obtain a copy of the document used?

In our state, driver’s licenses no longer include the person’s social security number. Would the bank need to make a copy of the identification (i.e., driver’s license) and attach it to the account opening documents, even if the license does not contain the social security number? If we use a credit bureau or similar report to verify the social security number and identity of the customer, would we then need to keep a copy of the report used?

The proposed rule for maintaining information used to verify a customer’s identity for 5 years after the account is closed will be very cumbersome and difficult to track, certainly for smaller community banks who maintain the documents in paper form.

We currently utilize a third party service for OFAC screening, but there is no such service available for the "control list" at this time. Therefore, the "control list" is checked manually. With the proposed rule requirements, please consider providing control list information to these third party providers so as to make this effort as efficient as possible.

The definition of an "account" states that the term is not intended to cover infrequent transactions such as the occasional purchase of a money order or a wire transfer. What is considered "occasional"? For example, if a non-account holder comes in to purchase a money order for cash every Friday to send to relatives in Mexico, would this be considered an "occasional" transaction under the proposed rules?

Please consider providing recommended language for notifying customers that the bank is requesting information to verify their identity.

Sincerely,

IOWA STATE BANK & TRUST COMPANY

Elizabeth S. Kuehl