427

Account Identification Information Exception

The Act does not require customer notice and a challenge opportunity nor does it impose restrictions upon interagency transfers where only basic account identification information is involved (i.e., name and address of customer, type of account, and account number). The government is required, however, to use some form of process, such as a formal written request, to obtain such account identification information. In addition to authorizing special access to account identification information for a specific customer, 12 U.S.C. § 3413(g) also permits more specific inquiries as to the account number associated with a particular financial transaction or class of transactions as well as accounts 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 indeed 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 for account identification information, this form includes a built-in certificate of compliance. Other forms of process (i.e., an administrative subpoena) may also be used to obtain account identification information.