WASHINGTON-Financial institutions should be able to choose whether to accept the matricula consular cards as a valid form of identification or not, CUNA Associate General Counsel Mary Dunn wrote in a comment letter to Treasury. "CUNA is aware that a number of concerns have been raised about the use of consular ID cards. While these issues should not be dismissed lightly, we do not believe they justify a prohibition against institutions using consular identification cards," Dunn wrote. "The treatment of consular identification cards under the final rule is fully consistent with the USA PATRIOT Act's language and intent." She suggested developing voluntary guidelines to help ensure compliance with Section 326 when accepting matricula consular cards. "Such guidelines should clarify that institutions may require an individual seeking to open an account to provide a U.S. passport or other official U.S. document to show identity, in addition to a consular identification card," she wrote. Treasury was seeking extra input on its final Section 326 rules of the PATRIOT Act regarding identification requirements. Dunn also said that CUNA opposed modifications to the final rule so close to the Oct. 1 compliance date.

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