[jcarter]

In the past I believe it was not allowed to view or keep a customers picture in a loan file or have it in the core system where a loan officer cannot view it. Is this still true? Can a loan officer view a identification such as a picture of the customer? we have had this come up and raises some questions as to if it is breaking any compliance rules by having the loan officer be able to view a picture of an customer or applicant. This opens some questions in discrimination as to what if they were to do a phone app. and the loan officer could view the information while talking to the customer, they could make an automatic judgment on wheather or not to make the loan. any feed bank would be greatly appreciated.
Thanks
Jacob Carter

[jholzknecht]

Jacob,

The concern is that having the monitoring information available is equivalent to collecting monitoring information. You are required to collect monitoring information for certain loans, but the practice is prohibited for other loans.

For CIP purposes you must verify your customer’s identity. You may do that by checking a driver’s license, among other methods. You must record the method of verifying the identity, but you are not required to keep a copy of the driver license. Keeping a copy raises the spector of a fair lending violation.

Most examiners will not cite a violation when the license is retained for CIP purposes. If you decide to keep the license, you are less likely to be challenged by an examiner if the copy is retained somewhere other than the loan file.

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