What is a Borrower Identification Form?

Borrower Identification Form is used to record the identification information of the borrower to establish the true identity of the borrower. The purpose of the form is to ensure the lender has obtained documentary evidence of the identity of the borrower. It is used to comply with the Customer Information Program (CIP) under the Bank Secrecy Act (BSA) regulations as well as to limit the incidence of identity theft. A separate form is used for each co-borrower.

At the time of closing, the closing agent (escrow officer, notary, or settlement agent) will ask the borrower to show identity cards or documents. The identification documents may include passport, driver's license, State Id cards, etc. The form is used to record the key identifying information from the documents such as document type, id number, state/country, issue date, and expiry date. Copies of identification documents are not required. For example, if the borrower provides driver's license then the closing agent will record the license number, issue date, expiration date, and other important details in the form. A copy of the driver's license is not retained.

Borrower's Considerations

Bring Identity Documents at Closing

It order to complete the Borrower Identification Form, the closing agent will ask you to bring at least two forms of identification at closing. It is the closing agent's responsibility to note down the information on the form. However, as a safeguard, you should review the form completed by the closing agent to ensure the information on the form is correct. Remember to take back your id documents back.

Lender's Considerations

Content

It is up to you to design the form since there are no laws, regulations, or investor guidelines that prescribe any form or content. The key consideration is to ensure that the form will capture the information needed to satisfy your Customer Information Program.

Timing

Most lenders require the closing agent to complete this form at the time of closing. For this reason, ensure the closing instructions require the closing agent to obtain the proper identification and complete the form.

Review

As part of your post-closing Quality Control process compare the information on the form with the information provided by the borrower in the loan application. Any discrepancy should be researched and satisfactorily addressed before funding.

Recordkeeping

If you are using the form for complying with BSA Regulations, then retain the form for at least five years after the date the account is closed.

Patriot Act Disclosure

The Patriot Act Disclosure is usually included along with the Borrower Identification Form since the disclosure provides the reasons for obtaining the identification information.

Applicable Regulations

Treasury regulation, 31 CFR 1020.220, contains the requirements to implement a written CIP and have procedures to require obtaining identifying information for each customer at the time of account opening.

Document Summary

Sample Documents

1. Sample Borrower Identification Form
2. Sample Borrower Identification Form And Patriot Act Disclosure

External Links

1. eCFR, Customer identification programs for banks, savings associations, credit unions, and certain non-Federally regulated banks. 31 CFR 1020.220

Updated: May 19, 2017