Account Identification Information Exception
The Act does not require customer notice and a challenge opportunity
does it impose restrictions upon interagency transfers where only basic
identification information is involved (i.e., name and address of customer,
of account, and account number). The government is required, however, to
some form of process, such as a formal written request, to obtain such
identification information. In addition to authorizing special access to
identification information for a specific customer, 12 U.S.C. § 3413(g)
permits more specific inquiries as to the account number associated with a
particular financial transaction or class of transactions as well as
associated with a foreign country or subdivision thereof. See 12 U.S.C.
3413(g)(2) for international financial transactions covered.|
This exception may be used to investigate transactions (such as check
forgeries) where a crime has been committed and it is necessary to trace a
financial instrument through various accounts to find the wrongdoer. In
addition, it will be useful to confirm that a financial institution does
have financial records sought in connection with a particular investigation
before action is initiated to secure access to the records.
Form DOJ-475 is suggested when making a formal written request
account identification information, this form includes a built-in
compliance. Other forms of process (i.e., an administrative subpoena) may
be used to obtain account identification information.