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Verifying ID: What should you accept?
by Mary Beth Guard, BOL Guru
In developing your Customer Identification Program under Section 326 of the USA PATRIOT Act, it will be important for your institution to identify the types of identification documents you will deem acceptable. You may wish to develop a master list, after discussion of the pros and cons of each type, and divide them into two categories: primary ID and secondary ID.
For maximum reliability, primary IDs should be government issued and should bear a picture of the customer. A customer could identify himself, for example, by producing one form of primary ID and one secondary ID. In order to be acceptable, the ID should be unexpired. Since some IDs (such as the recently issued military IDs) no longer bear a signature of the individual, you'll want to request another form of ID that gives you a specimen signature. By the same token, since many driver's licenses and state IDs no longer include a Social Security number, you will need to either look to a second document to verify the SSN, or you will need to use a third-party database to confirm the number given to you.
In addition, you should educate your frontline personnel about how to examine an ID, and should equip your staff with the resources necessary to determine the validity of identification documents that are issued by someone other than your state.
To help you get started, we've provided a laundry list of possibilities and have tentatively categorized them as either primary or secondary IDs. It's up to you to decide which will be acceptable to you.
Primary ID
- driver's license
- state ID
- commercial driver's license
- military ID (three forms)
- federal government employee ID cardspassport
- permanent resident card
- alien registration card
- Nonresident alien border crossing card
- Nonimmigrant visa and border crossing card
- Employment authorization card
- matricula consular card
Secondary ID
- Social Security card
- voter registration card
- credit card
- student ID
- employer-issued ID
- property tax bill
- utility bill
- firearm license
The original version appeared in the March 2003 edition of the Oklahoma Bankers Association Compliance Informer.
First published on BankersOnline.com 8/25/03
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