Retention of Photo ID

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    What if, any is the regulation or language that addresses the retention of government issued photo ids in a mortgage loan file. There seems to be conflicting information about whether or not a government ID can even be printed much less retained.


    Having a copy of a photo ID in file can be considered as collecting Monitoring Information. If the loan requires or allows for the collection of monitoring information, then you should be fine.

    However, on consumer loans where you don’t collect race, ethnicity, and sex information; the presence of a photo ID could be considered as collecting monitoring information and be a violation.


    You also need to review your bank’s BSA rules for CIP – there may still be language in the policy that states you are getting copies of identification for new customers. Your BSA officer may not be concerned with the Fair Lending concerns of having copies of ID in lending files, especially if underwriting has access to the copies. Sometimes we put blinders on when it comes to the regulations we are responsible for.


    Great addition cmitchell!

    Typically the violation would occur if it is kept in the loan file. If ID for BSA reasons is kept on in the Deposit side of the house, then I wouldn’t anticipate any issues.

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