An Account Opening Question: Must Member ID Images Be Deleted?

ARLINGTON, Va.—When opening accounts online, must credit unions delete a copy or image of a member's identification card after the verification process?

Brandy Bruyere

NAFCU said its compliance team continues to receive questions about the "making online banking initiation legal and easy" section of the Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155).

Brandy Bruyere, NAFCU vice president of regulatory compliance, explains that this section within S. 2155 is a "freestanding provision … it does not amend a pre-existing statute or framework – it is not clearly incorporated into an existing part of the U.S. Code that addresses issues like civil liability, regulatory authority and enforcement."

“In other words, there are no stand-alone penalties or requirements to delete a member's ID card after it is used to verify their identity, among other uses,” she said.

NAFCU noted that another resource for S. 2155 compliance available to credit unions is its detailed summary guide of the law, featuring provisions, their effective dates and other details.

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