"No-doc" loans and customer ID procedures.(MAILBOX)(Brief article)

From: ABA Banking Journal | Date: October 1, 2007| Author: | Copyright information

Q. My bank has a customer due-diligence policy that requires individuals opening accounts to provide us with their occupation and employer. Generally, this is easy to capture as part of the account opening/loan application process. However, it has come to my attention that our mortgage loan division offers "no doe" or "stated income" loans that do not require or capture the employer, occupation, or income information. How should my bank perform customer due diligence?

A. The Bank Secrecy Act Customer Identification Program regulations require that you obtain the name, ...

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