Verification of Cardholder Identity. 4.9.1 The Merchant will not effect a Transaction with a Cardholder unless that Cardholder’s identity is verified as outlined in this clause.
Verification of Cardholder Identity. (this function is not performed by the Credit Department, but rather by the Risk & Compliance Department) FinCEN’s Prepaid Access Rule imposes certain customer identification program (CIP) obligations on providers (and sellers) of prepaid access. Providers (and sellers) of prepaid access must establish procedures to verify the identity of a “person who obtains prepaid access” under a prepaid program which is not exempt, and to obtain identifying information concerning such a person, including name, date of birth, address and identification number. Providers of prepaid access must retain access to such identifying information for five (5) years after the last use of the prepaid access device or vehicle. For nearly all of Comdata’s prepaid card programs, the “person who obtains prepaid access” is Comdata’s Customer. Comdata’s policies, procedures and controls with respect to the identification, verification and additional due diligence procedures for such Customers is described above. In limited circumstances, the person who “obtains prepaid access” is the cardholder (the “Cardholder”) as a result of a statutory contractual relationship with Comdata’s Customer (e.g. certain payroll card programs). With respect to these Cardholders and where the underlying prepaid program is not exempt, Comdata has established procedures for verification of the identity of a Cardholder and access to the information used to verify the identity of a Cardholder. Where required, Comdata requires its Customers to verify the identity of a Cardholder, to collect identifying information about Cardholders, and to maintain access to such information. Additional Screening Procedures for Customers
