SentiLink encourages modernizing the requirements around identity verification in a statement submitted to the House Financial Services Committee for their hearing, "Oversight of the Financial Crimes Enforcement Network."
- CIP rules should provide greater clarity and specificity with regards to what constitutes a "reasonable belief" of identity verification, and should focus on the changing nature of the actual criminal threats financial institutions face, agnostic to the specific product or service for which a consumer is applying.
- Checks for synthetic identity fraud should be a core feature of CIP rules, FAQs and guidance.
- CIP rules should reflect the reality of the changing nature of identity fraud, and require the collection and additional verification of address, phone or e-mail, depending on the means by which an institution contacts their customers.
Read the entire comment here.