CCUL Compliance on matricula consular, CIP policy
Wednesday, November 15, 2017
Last week's Weekly Compliance Question regarding matricula consular cards as an acceptable form of identification invoked several responses from credit unions, prompting the need to provide additional information for clarity.
Section 326 of the USA PATRIOT Act is what governs a credit union’s Customer Identification Program. Under the USA PATRIOT Act, a credit union must acquire an unexpired government issued ID with a photograph for verification before opening an account. Therefore, under this definition, a matricula consular card is an acceptable form of documentation.
The USA PATRIOT Act gives credit unions the flexibility to decide what types of documentary and/or non-documentary methods it will use to form a reasonable belief that a member is who they say they are. Each credit union should do their own risk assessment based on their size, complexity, and type of member base and incorporate their own policies and procedures and determine what types of documents and IDs you will accept. After doing this risk assessment, each credit union will need to determine the minimum acceptable documentation in their policy and procedures. Credit unions are also encouraged to review more than one single document to ensure the identity of the member, due to increasing fraud. Because there are so many different forms of identification out there, FinCEN has issued guidance on CIP procedures.
Additionally, our 2018 BSA/AML Conference will have sessions relating to IDs and your Member Identification Program. Register before the end of the month to receive a $50 discount.
FinCEN - USA PATRIOT Act
FinCEN - FAQs Final CIP Rule
FinCEN - Guidance on Customer Identification Regulations FinCEN FAQs: Final CIP Rule
FFIEC - Customer Identification Program Overview
NILC - Basic Facts about the Matricula Consular