IBA Compliance Connection

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We do not currently provide a copy of a signature card to an account owner or business owner unless they request it. Should we be providing a copy of the signature card at account opening and when any changes are made? Our signature cards contain the information we collect as part of our Customer Identification Program (CIP), including tax identification numbers. Could there be any issues associated with providing this information to all authorized signers on an account?

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We recommend providing signature cards to customers at account opening and when changes are made to the signature card, but this decision does depend on whether your signature cards incorporate contractual language that your customer is agreeing to.

We are not aware of any laws or regulations that would require you to provide copies of signature cards to account owners or any guidance from regulatory agencies recommending that institutions provide them. Signature cards are often designed to assist tellers and back office personnel to confirm signatures of authorized signers on an account and collect CIP information, but they also can incorporate contractual terms that the customer agrees to by signing the card.

If your signature cards do include contractual terms, we highly recommend providing a copy to the customer so that they have a record of the contract that they have signed. This would also allow your bank to argue that your customers were aware of any provisions contained in the cards in the event that a dispute later arises. It also may be beneficial to provide copies of signature cards so that your customers may verify the authenticity of their signatures and the CIP data provided.

Additionally, you may choose to limit the kind of information that appears on signature cards when providing copies to authorized signers who are not account owners. We recommend caution before sharing CIP and other account information with non-owners, such as an authorized signer, in light of financial privacy protections.

For resources related to our guidance, please see:

  • Illinois Banking Act, 205 ILCS 5/48.1(c) (“Except as otherwise provided by this Act, a bank may not disclose to any person, except to the customer or his duly authorized agent, any financial records or financial information obtained from financial records relating to that customer of that bank unless: (1) the customer has authorized disclosure to the person.”)
  • IDFPR Interpretive Letter 01-01 (March 9, 2001) (“Section 48.1 only uses the term ‘customer’ but does not define the term for purposes of the section. However, the plain language is clear. All customers (individuals, corporations and other entities) are protected whether they receive a financial product or service from a state bank or seek to obtain such product or service for personal or business purposes.”)