Black_Adder
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Identification
The Guidance Notes for Credit Unions on Compliance with Criminal Justice (Money Laundering & Terrorist Financing) Act 2010 suggests that a trigger event such as a new loan is when “…the credit union should review the appropriate identification data held …” and this is not the same thing as demanding that fresh Verification of Address (‘VoA’) and Verification of Individual (‘VoI’) are obtained.
The Act in fact is quite explicit:
The CJA 2010 (S. 33(1)(d)) requires that CDD be applied to existing customers where there exist:
“…reasonable grounds to doubt the veracity or adequacy of documents or information previously obtained for the purposes of verifying the identity of the customer.”
In simple positive terms this could be stated as:
You do not require CDD where you are satisfied on reasonable grounds as to what you have. The practice that many Credit Unions apply regarding CDD is as if they do not believe that have reliable information already.
In addition, the Guidance states:
“…There would not be a rationale for any immediate mandatory overall retrospective establishment and verification of identification for all members…”
QUESTIONS -
Why are many Credit Unions obsessed such that ever single time you get a loan they are asking for fresh copies of VoI and VoA
(a) Do they just do it to annoy members?
(b) Are compliance gone insane?
(c) A pushy Central Bank demands that they do
The Guidance Notes for Credit Unions on Compliance with Criminal Justice (Money Laundering & Terrorist Financing) Act 2010 suggests that a trigger event such as a new loan is when “…the credit union should review the appropriate identification data held …” and this is not the same thing as demanding that fresh Verification of Address (‘VoA’) and Verification of Individual (‘VoI’) are obtained.
The Act in fact is quite explicit:
The CJA 2010 (S. 33(1)(d)) requires that CDD be applied to existing customers where there exist:
“…reasonable grounds to doubt the veracity or adequacy of documents or information previously obtained for the purposes of verifying the identity of the customer.”
In simple positive terms this could be stated as:
You do not require CDD where you are satisfied on reasonable grounds as to what you have. The practice that many Credit Unions apply regarding CDD is as if they do not believe that have reliable information already.
In addition, the Guidance states:
“…There would not be a rationale for any immediate mandatory overall retrospective establishment and verification of identification for all members…”
QUESTIONS -
Why are many Credit Unions obsessed such that ever single time you get a loan they are asking for fresh copies of VoI and VoA
(a) Do they just do it to annoy members?
(b) Are compliance gone insane?
(c) A pushy Central Bank demands that they do