Okay, I'm back to square one. After the PB views and records the driver's license, don't we have to verify that information somehow? We have been doing it thru ChexSystems since they report back the name the driver's license is issued in if from our state. I thought all along that we had to verify the documents we used for identification and I know of no other way to do it since we don't use an anti fraud system. We have been verifying documents on entities such as articles of inc through the state website. Isn't verification required and how are other banks doing it? Also doesn't the policy have to say exactly how we're verifying? As you can tell, I am questioning myself since our written procedures are being questioned. And if the address is different now from what is on the DL, is that considered a discrepancy? Thanks

The regulation states that you can trust a goverment issued ID to be accurate for identity purposes. However if information on the ID such as address does not match the customers current address you need to document the reason for the discepancy such as just relocated to town, college student temporary address etc. As to additional verification of th ID presented you must follow whatever your CIP policy says. Verifying indentity simply means looking at a governement issued ID and making sure the picture on the ID matches the person you are dealing with and recording the required information about the ID used.

So, in essence, you don't have to verify the information you used to ID the person?

If the ID is a Government Issued photo ID, no, unless your CIP states otherwise. Our CIP states simply states that we have to see a government issued photo ID and record all of the required info. If there is a discrepency in address etc we must document why the information provided does not match the info on the photo ID.

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After the PB views and records the driver's license, don't we have to verify that information somehow?

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What you are responsible for verifying is the customers' name, address, DOB and identifying number to the extent necessary to form a reasonable belief of their identity. The supplementary information accompanying the CIP regulations clearly indicates there is no requirement to authenticate the document you used to verify that information:

Treasury and the Agencies wish to confirm that once a bank has obtained and verified the identity of the customer through a document such as a driver’s license or passport, the bank will not be required to take steps to determine whether the document has been validly issued. A bank generally may rely on government- issued identification as verification of a customer’s identity; however, if a document shows obvious indications of fraud, the bank must consider that factor in determining whether it can form a reasonable belief that it knows the customer’s true identity.

So, if you accept a New York drivers license that is a "good" fake, government regulations do not require you to do more. It's your common sense that is suggesting that at least a nominal verification of ID, whether it's a driver's license or a corporate certificate of good standing, is necessary.