CUNA Regulatory Comment Call


June 30, 2003

Treasury Department Seeks Additional Comments on Member/Customer Identification Program (CIP) Regulations

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE REQUEST FOR COMMENTS

Photocopying

  1. Should the regulations require financial institutions to make and maintain a photocopy of identification documents upon which the financial institution relies to verify identity in all cases?

    Yes ______ No ______

    Please explain why or why not.













  2. Should the regulations identify specific instances in which photocopies of documents relied upon must be made and maintained?

    Yes ______ No ______

    Please explain why or why not.













  3. Should the regulations provide guidance to financial institutions concerning risk factors indicating when photocopying identification documents relied upon may be appropriate?

    Yes ______ No ______

    Please explain why or why not.













    Matricula and Other Forms of Identification

    Regarding Matricula and other forms of identification issued by foreign governments, the regulators are seeking additional comments on:

  4. Should the regulations preclude financial institutions' reliance on certain forms of identification issued by certain foreign governments?

    Yes ______ No ______

    Please explain why or why not.













  5. Should the regulations require financial institutions to obtain a passport number from all customers who are non-U.S. citizens?

    Yes ______ No ______ Please explain why or why not.













  6. What are the anticipated effects on non-U.S. citizens in the United States who are not required to have a passport?

    Yes ______ No ______

    Please explain why or why not.













  7. What are the anticipated effects on non-U.S. citizens who open accounts from broad, and thus are not required to have a passport?

    Yes ______ No ______

    Please explain why or why not.













Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com