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hi my name is adam whitmer im the founder and host here compliancecohort.com now this compliance clip is going to talk about keeping photo ids in your loan files and whether or not that is permitted so the question we received is now that we have to get verification for beneficial owners is it permissible to keep copies of photo ids in a loan file so this is a question weve actually received many times over the years and really the beneficial ownership parts of this question is irrelevant the question is whether or not its okay to keep photo id copies in a loan file whether or not beneficial ownership is involved because this really goes back to the early 2000s when he had we had to implement the cip rules and get verification and a lot of organizations made copies of photo id so can we keep those in the file now why would this be a concern well the concern would come from a fair lending concern because over the years some examiners have accused financial institutions of having copi