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CIP Identity Verification
Answer by John Burnett, BOL Guru
BIO AND CONTACT INFO
Question: In the Office of Thrift Supervision's CIP "A Staff Summary and Answers to Questions," the Treasury writes, "In addition to collecting the required information, thrifts must verify the identity of the customer using the collected information" (pg 4 of 9). I thought that the identification number collected (SSN, passport number, etc.) was different from the documents used to verify the identity. If you obtain a driver's licence number as an identification number, I would think you shouldn't (?) verify his/her identity with the same document... Please explain.
Answer: The driver's license can be used to verify information other than the license number. For example, in some states, the license number may be the same as the individual's SSN. That can help confirm the SSN. The photo on most licenses can be compared with the appearance of the individual if face-to-face. The address on the license is usually a residence address that can be compared with the address the individual has given you. The spelling of the name can also be compared, as can the DOB.
Of course, there's the possibility the customer has recently moved and the address won't agree. But you still have the other elements.
First published on BankersOnline.com 9/8/03
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