We believe that the CIP regulations permit a bank to accept Illinois temporary paper IDs as valid identity documents, but your bank also may choose to not accept temporary paper IDs as a matter of policy.

 

The CIP regulations require your bank to verify an individual’s identity after account opening. If verifying an individual’s identity through documents, you may use an “unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport.”

 

Under the Illinois Secretary of State’s new centralized process for issuing Illinois driver’s licenses and state identification cards, individuals renewing an ID initially will receive a temporary paper ID and the individual’s expired ID (with a hole punch). In Illinois, the temporary paper IDs will include the individual’s photograph and other security features. Consequently, we believe that the Illinois temporary paper ID is sufficient to serve as an “unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard,” particularly when the individual’s expired ID is used as well.

 

However, your bank is not required to accept temporary paper IDs and may choose to not accept them. In addition, we do not believe it is necessary to require customers to return with their permanent IDs after receiving them — but again, your bank may choose to require this as a matter of policy.