{"id":2143,"date":"2020-06-19T15:20:35","date_gmt":"2020-06-19T15:20:35","guid":{"rendered":"https:\/\/albanknews.com\/?p=2143"},"modified":"2020-06-19T15:20:35","modified_gmt":"2020-06-19T15:20:35","slug":"compliance-qa-ppp-application-and-expired-id","status":"publish","type":"post","link":"https:\/\/albanknews.com\/?p=2143","title":{"rendered":"Compliance Q&A: PPP Application and Expired ID"},"content":{"rendered":"

Q:<\/strong> The bank has received an application for a Paycheck Protection Program (PPP) transaction.\u00a0The beneficial owner of the business is not a signor or guarantor. His ID provided is expired and he doesn\u2019t wish to provide a new copy.\u00a0Is this a BSA violation if the bank does not obtain an updated ID from him?<\/p>\n

A:<\/strong> The CIP regulations do not provide that the only way to verify identification is with an unexpired ID.\u00a0 The regulations list an unexpired ID as an example of a way to verify identification (“documents\u00a0may\u00a0include”), but it is not the only acceptable way to verify information with documentary evidence.\u00a0 The regulation allows each bank to create a policy that fits their own needs using both documentary and non-documentary evidence, so your scenario is not necessarily a violation of BSA, although it may be an exception to internal Bank policy.<\/p>\n

(ii)\u00a0Customer verification.\u00a0The CIP must contain procedures for verifying the identity of the customer, using information obtained in accordance with paragraph (a)(2)(i) of this section, within a reasonable time after the account is opened. The\u00a0procedures must describe when the bank will use documents, non-documentary methods, or a combination of both methods\u00a0as described in this paragraph (a)(2)(ii).<\/em><\/p>\n

(A)\u00a0Verification through documents.\u00a0For a bank relying on documents, the CIP must contain procedures that set forth the documents that the bank will use. These documents\u00a0may\u00a0include:<\/em><\/p>\n

(1) For an individual, unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport;<\/em><\/p>\n

31 CFR 1020.220(a)(2)(ii)\u00a0https:\/\/www.ecfr.gov\/cgi-bin\/text-idx?SID=ac10085d2bd1b4586c54b8a9ed47d5f5&mc=true&node=se31.3.1020_1220&rgn=div8<\/a><\/p>\n

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