In our magazine, Banking on BCC, there was an article that arose from a conversation with an institution through our Quick Response Consulting Service. The question was in reference to Military Identification cards (ID) and Customer Identification Program (CIP) requirements. In this particular situation, a new customer provided their Military ID as their primary form of identification. In line with the institution’s record retention practices, the employee opening the account was going to make a copy of the Military ID for the file.
Keep in mind, Military IDs contain sensitive personal data, even to a greater extent than a driver’s license and Federal Law does prohibit the photocopying of Military IDs. There are actually some states out there that restrict and limit the photocopying of driver’s licenses as well, but photocopying Military IDs is always off limits.
So, what do you do in these instances?
Under the CIP requirements, institutions are not required to make a photocopy of any document relied upon; rather, institutions are required to record the applicable information from the document and keep a record of: ...the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date....Institutions typically make copies as it is quick and easy; however, a more manual process would need to be utilized in the case of Military IDs.
Published
2025/11/03
