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Per regulation B (not HMDA), is it a violation if the bank receives an image of a driver’s license with an online application when GMI information is not allowed to be collected?
Some financial institutions keep a copy of a driver’s license for CIP purposes. CIP regulations do not require a copy of a driver’s license. Regulation B does not prohibit the practice of photo copying or digitally storing photo identification, but it does prohibit the collection of certain demographic information. Given that photo identification usually contains this prohibited information, it is a best practice not to retain a copy of the photo identification. However, if a bank chooses to retain a copy of photo identification, it is best if it is segregated from loan files.
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