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January 11, 2017


Kat Cuoco

This is a great post!
A few comments:
In recent discussions with examiners, they have noted on several occasions that they don't find keeping a copy of the member's ID a fair lending issue-IF we are consistent in doing this with the majority of our members. This is especially helpful when doing Indirect Loans, as a copy in the loan file proves that the DL was collected at loan application (since they don't visit a cu office).
Another monkey wrench: in NM there are issues with providing car loans to those whose licenses have been revoked due to DWI. Collecting the license they provide to us (and documenting) proves we conducted our due diligence. Also, if there is a keying error with any CIP issues, this is helpful to correct it without bothering the member.
Having a copy of their ID on file is also convenient for members, especially in situations like you noted above. For me, I like having my DL on my account, that way if someone tries to imitate me, my smiling face pops up on my account first.

Have a great day!

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