[crzyabtcmplnce]

Are any of you requiring your new account customers to sign the Patriot Act Disclosure? We are seeing this all of a sudden and hadn’t in the past. We have the disclosure on each desk, but we were not getting them signed. We have noticed them on some real estate closings from title and mortgage companies.

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[JGo9]

It has been my experience that most banks do not have customers sign a document for the Patriot Act. Most just have the notice on the desk.

[Anonymous]

I have a question about this in relation to mortgage loans. We have been told by our outside audit firm that reviews our mortgage loans files that we must have a signed disclosure in the file as well as a copy of the ID we used to verify the customer. I could not find anything in regards to that requirement in any of my compliance research. Is this correct?

[jholzknecht]

Ask your audit firm if their position is opinion or regulation. If they state it is regulation, then they should be able to supply citations that direct you to the answer. I think you will find this is their position.

[Author]

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