Many credit unions have had questions about properly identifying members in the face of lobby and branch closures related to coronavirus (COVID-19). Bank Secrecy Act (BSA) member identification (ID) procedures require credit unions to have, at a minimum, the name, address, date of birth, and an ID number for each member.
In an increasingly diverse culture, verifying this information often requires flexibility, as well as policies and procedures that provide guidance.
“If you don't reasonably believe you know the true identity of a member, you can ask for more information,” says Colleen Kelly, CUNA’s senior federal compliance counsel. “This may be the case when you’re working with non-U.S. citizens.”
She describes several acceptable forms of member identification.
This card should contain the bearer’s photo on the front and back, name, U.S. Custom and Immigration Service number, date of birth, card expiration date, and laser-engraved fingerprint.
Some of these features are present only on permanent resident cards issued after May 1, 2017.
“You’re still going to see a lot of green cards with the previous design,” Kelly says. “They’re still valid, and they have all the information you need to comply with the BSA requirements.”
Foreign consulates issue these cards to identify citizens living abroad. They’re issued regardless of the applicant’s immigration status.
Each cardholder is given a unique identification number that is displayed on the card. In general, these cards also include the cardholder’s photo, address, birthplace, and expiration date.
“Ultimately, the credit union will decide, based on appropriate risk factors, whether to accept this form of ID for BSA purposes,” Kelly says.
The U.S. does not issue consular ID cards, but has recently begun to issue U.S. passport cards.
These cards are limited to domestic travel, and travel to Canada, Mexico, and some Caribbean countries. For identification purposes you must request to see the member’s actual U.S. passport.
Formulated in the wake of the Sept. 11 attacks, Congress passed the REAL ID Act in 2005 to “set standards for the issuance of sources of identification, such as driver’s licenses.”
State agencies that issue licenses and identification cards, such as departments of motor vehicles, now require more paperwork regarding proof of residency and Social Security numbers.
Because each state has its own licensing process, the REAL IDs have been phased in over the past few years. By Oct. 1, 2020, all state IDs should have the star at the top of the card.
“Real IDs are required for international travel and to enter federal facilities,” Kelly says. “The credit union’s policies and procedures will determine whether a REAL ID is required for BSA compliance purposes.”
Over the past decade, some cities have introduced municipal IDs to help residents without driver’s licenses to gain access to local benefits, such as homeless shelters, food assistance, and library services.
Some states encourage financial institutions to accept local IDs for opening checking and savings accounts.
“Like any identification card, it will be up to the credit union to determine whether these local ID are acceptable,” Kelly says. “At a minimum, you should ensure that it has been issued by a government agency, has not expired, and includes the name, address, date of birth, and an identifying number.”
Foreign passports are the most commonly accepted form of foreign identification.
“A credit union must determine its risk tolerance for excepting a variety of foreign passports,” Kelly says. “Do you have the resources to verify a particular foreign passport? Will you require that it be stamped by the U.S. Custom and Immigration Service? Will you accept any foreign IDs that are printed in another language?”
As the world becomes more sophisticated, more types of identification will likely be presented, Kelly adds. “It’s important for credit unions to carefully update their policies and procedures, and stay up to date with new ID technology and security features.”
Kelly addressed the 2019 CUNA BSA/AML Certification Conference with NASCUS.