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FDIC Federal Register Citations

September 4, 2002

This comment relates to the USA Patriot Act - Consumer Identification Programs (CIP):

1. Identification problem-A sweet little old lady opens an account and adds her two children to the account, "In case something happens." These adult children live far away in other states. Generally signatures are verified for the signature card by written means using notaries, etc. How can a financial institution verify identity on these two individuals? This happens EVERY day.

2. What about Pay on Death (POD) accounts. That same little old lady puts her children on as POD, we don't obtain their signature, many POD's don't even know they are POD's. Will we be forced to obtain their identity? That would harm the consumer because many don't want their children to know they added them as POD.

3. Please don't make us identify and retain identity records for people who inquire about accounts but don't really open them. You need to be reasonable, unlike OFAC rules which technically require us to run the name of a person who comes in the doors of the bank seeking change for a $50, that's absolutely rediculous.

4. Records should not need to be kept longer than 2 years, as opposed to the 5 year suggestion in the proposed reg.

5. Requiring financial institutions to copy and retain drivers licenses is burdonsome and impractical and may be illegal in some states. All this provision says is we don't trust financial institution employees so we are going to require something that our regulators can track, copies. There is absolutely no use for this copy 99.99% of the time and, as usual, the regulations only really help in .01% of the situations. That's like punishing the masses for the crimes of one. It won't help because criminals can easily get around this identification problem by simply having fake identification. If they have all the proper documentation, how do we verify that it is real?

Leo R. Kringle, SVP
Sherman County Bank
PO Box 543
Loup City, NE 68853
(308)745-1500 745-1655 fax

Last Updated 09/05/2002 regs@fdic.gov

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