I am in the process of auditing our BSA program. Upon examining the new membership applications, we require at least two forms of identification. Primary must be a government issued identification and a secondary form of identification. I am observing, “Work ID” or Work Paystub” as the second form of identification. No note as to the identification of the employer. If requested, how can we produce evidence of the secondary identification if we do not list an employer on the application nor a work telephone number. Given the availability of counterfeit and fraudulent documents, how can the credit union form a “REASONABLE” belief in the identity of the member with identification that we have no way of verifying, say three months or more later? Before I start stirring the pot, I am thinking about requiring MSR’s to list the employer name and telephone number of the employer “IF” they are using employment ID as the secondary ID. (Unless it’s one of our SEG’s)Any thoughts?
June 6, 2012 - 11:53am
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