Patriot Act

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    On our first intake appointment, we were given an action plan. One item said:

    “Provide a letter of explanation addressing why the ID does not list your current address and attach a utility bill or bank statement that has been mailed to your current address to verify residency, if you cannot provide a utility bill or bank statement you must change the address on the ID to match your current address to comply with the Patriot Act requirements.”

    My husband and I submitted 1 document each (me using my bank statement and him using the water bill).

    We recently received an email providing us with a heads up that it could be an issue by the time our application gets to the bank and that Under the Patriot Act we will need to be able to provide two compliant documents to verify where you currently live, such as photo ID, bank statements, or true utilities (i.e., electric, gas, water, home phone).

    Okay at first it was one document per the Patriot Act. Now we are being told two. When I questioned it, we were told it was the original policy. So I am assuming a policy change. Can someone please help me and tell me if it is one document or now two documents?

    Hoping someone or @ttrumble can help!


    I’ve purchased 3 houses. 1 through FHA first time home buyer program, 1 through a conventional loan with 30% down payment and now 1 through NACA. I’ve never had to provide less than 2 documents…


    If you read through the Patriot Act there is no requirement for providing a certain amount of documents. The requirement is for the financial institution to verify the borrower’s identity and determine their own criteria for doing so.


    “There is no set number of forms of ID required by the USA Patriot Act. Section 326 of the USA Patriot Act requires financial institutions to implement a Customer Identification Program (CIP) that is appropriate for the size and location of the financial institution. This regulation requires the CIP to be in writing, incorporated into the institution’s Identity Theft Prevention and Red Flags program, and approved by the Board of Directors, a committee of the Board of Directors, or Senior Management.

    A financial institution must implement reasonable procedures for verifying the identity of any person who applies for a residential or commercial mortgage loan. These procedures may vary based upon the circumstances of each situation and whether any “Red Flags” are present based on the information obtained by the financial institution regarding the consumer.

    It should be noted that the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network, National Credit Union Administration, Office of the Comptroller of the Currency, Office of Thrift Supervision, and the United States Department of the Treasury have recommended that “given the availability of counterfeit and fraudulently obtained documents, a bank is encouraged to obtain more than a single document to ensure that it has a reasonable belief that it knows the customer’s true identity”. [Interagency Interpretive Guidance on Customer Identification Program Requirements, April 28, 2005.]”


    Hello RAnthony,


    The text of the original condition you quoted is boilerplate text used for that particular issue.

    In reality there should be virtually no reason for everything to not have the same address, which is why it raises a red flag and is literally addressed in the Patriot Act. Invest a little time and effort making sure all active accounts and forms of ID, Social Security and even your paystubs all have the same address. It will make the process easier at several points along the way.

    Tim Trumble
    Online Operations, NACA


    Thanks for your response @ttrubmble. We use our mother’s address for mostly important things due to moving because we stay in apartments and usually things get lost in mail during the transition period between apartments. My husband and I both had our own apartments and then I moved in with him. Everything was already established, therefore I did not get my name added to the lease or the bills due to most times it requires a credit check which would then be a hard inquiry. My paystub has the current address on it but I was not aware that would be sufficient enough for one of the documents.

    Thanks you for your help!

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