Overview
BEFORE you can release information to an individual claiming to be a client, you must first verify their identity. You can always base identity upon your personal knowledge or if the caller provides you with the Inquiry Identification (ID) Code (IID) listed on their CIF record as well as the last 4 of their Tax Identification Number (TIN).
In other cases, to ensure that you are speaking with the client, the caller MUST be able to give you at least 3 of the identifiers listed for the type of account in question. One of the identifiers requested should ALWAYS be the TIN (social security number for consumers), since someone who finds a checkbook or steals a check would not know that information, and we should be very suspicious of any caller who cannot supply their TIN. Many clients are wary of giving you their entire TIN# so the last 4 digits with 2 additional identifiers are sufficient.
The release of information and identification falls under the purview of the Gramm-Leach-Bailey Act (GLBA), also known as Regulation P. For more information and full identification procedures, see GLBA ID and Information Release Procedures.
Identifiers for Deposit Accounts
- Tax Identification Number (TIN) or Last 4 digits of TIN (MANDATORY)
- Inquiry ID Code
- Account Number
- Date of Last Deposit
- Date of Birth
- Amount of Last Deposit
- Recent Debit Card Activity
Best Practice: Associates cannot prompt transactions, the client must provide the information. It is recommended to get 3-4 account level activities.
Identifiers for Loan Accounts
- Tax Identification Number (TIN)
- Loan Number
- Amount of Last Payment
- Date of Last Payment
- Date of Birth
- Collateral Information (for example: address of property, make of vehicle)
Information on Credit Cards
Associates with access to Elan information will use a combination of 3 of the following as identifiers for credit card callers:
- Last 4 Digits of the TIN
- Last 4 Digits of the Credit Card Number
- Home Telephone Number or Business Phone Number
- Credit/Revolve Limit
- Number of Cards on the Account
If the associate is unable to assist the client and needs assistance from Elan contact Card Member Services.
- Personal Accounts: 1.800.558.3424
- Business Accounts: 1.800.558.8855
Phone Script
Opening:
- Banker - Thank you for calling Capital City Bank. This is your banker____________. May I ask who I'm speaking with today?
- Client - Client response.
- Banker - Thank you, Mr/Ms _________. May I please have your account number or your social security number?
Flow Chart
- Do not provide callers inquiry ID codes, no exceptions
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Do not release prompted additional information, this would include the following:
- The existence of additional signers of beneficiaries, additional accounts, whether they are personal, business account types, or numbers
Inquiry ID Codes
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Never accept an inquiry ID code or any identifying information provided by anyone other than the client.
- This includes the client providing information from the background of a conversation.
- If the client cannot immediately recall their inquiry ID code, a good trick is to say:
- "If you were to set up a verbal ID code today - What word, name, or number would you use?"
- Sometimes this can aid in jogging the client's memory.
- Control calls by only allowing the caller to make a maximum of 3 attempts at guessing their inquiry ID Code. If after 3 attempts they cannot recall, please move forward with sending a phone access code (PAC).
Third Party Calls
When a merchant, payday loans company or individual call to verify funds with the client on the line, do the following:
- You MUST verify the client with a PAC instead of the Inquiry ID Code.
- Ask the client if it is OK for you to speak with the merchant, on their behalf, regarding the transaction(s) they are inquiring about.
- Click here for details on providing Funds Verification by Phone.
You CAN NOT provide verification on any other information (for example: address, account balance, recent deposits or account numbers). You CAN NOT provide yes/no answers even if the merchant or client is providing information.
Special Circumstances
Unable To Obtain an Inquiry Code or Send PAC
- Ask if the need is general or account-specific.
- If account-specific and the client have a Bank Online (BOL) account, encourage them to log in and chat with an associate. Note: This authenticates them.
- Ask if the client has a trusted banker at a local office that can recognize their voice over the phone.
- You are able to use recent transactions, merchants, and amount, not counting Social Security Insurance (SSI) to verify the client. You can use the sentence, "Let me try another method to identify you." before offering this option.
- If you were unable to fully identify the caller, select the "Unable to identify" wrap-up reason in Finesse. Add a message to the account that says "Unable to verify by phone. Note: Please update the ID code and all contact information will help the office associate obtain updated records for the client so we assist by phone next time.
Dealerships
See flowchart, but with loan number, SSN, loan holder's name, year, make, and last six of the VIN number, we can provide payoffs.
Non Client Loan Payments
Payments can be accepted if we have the loan number, SSN, name on the loan, year, make, model, and the amount the caller wants to pay. The caller must also provide paying bank information.
Watch for Fraud
- Phone numbers and caller IDs can be spoofed
- Note: If you have an uneasy feeling, call the client's number on file. Check previous call recordings to make sure voices match, and require a PAC
- If there are multiple calls in a short period of time, tread carefully. Also, be on the lookout for calls coming from a client who does not call frequently or has never called in before
- If anything feels fishy or contradictory, ask a manager for assistance or to listen in on the call