In this week’s InfoSight newsletter, one article focuses on federally non-compliant state IDs and MIP. As a result of the REAL ID Act, some states are issuing identification cards that note across the top, for example, “not effective for federal purposes” or “not acceptable for identification purposes.” Are these cards acceptable for purposes of your credit union’s Member Identification Programs (MIP)?
According to FinCEN, that is going to depend on whether the credit union has included the acceptance of these IDs in its written MIP program. Credit unions may determine, by written policy, the type of IDs it will, or will not, accept based upon the credit union’s risk.
The REAL ID Act, passed by Congress in 2005, enacted the 9/11 Commission’s recommendation that the Federal Government “set standards for the issuance of sources of identification, such as driver’s licenses.” The Act established minimum security standards for license issuance and prohibits Federal agencies from accepting non-compliant state issued identification cards for certain purposes. The purposes covered by the Act are: accessing Federal facilities, entering nuclear power plants, and boarding federally regulated commercial aircraft. Since the list of purposes does not include the Bank Secrecy Act compliance programs, you are not prohibited from accepting these identification cards.
Read the full InfoSight newsletter here.
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