Using Existing CIP Procedures to Verify Identity
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Can we use existing CIP procedures to verify identity? What if this is an existing customer? Can we rely on what we did for CIP if this CIP info is current (say within 30 days)?
Answer: Part of your responsibility for dealing with address discrepancies is to form a reasonable belief that a consumer report relates to the consumer about whom it has requested the report. One acceptable method of completing this task is to comparing the information in the consumer report with information you obtain and use to verify the consumer's identity in accordance with the requirements of the Customer Information Program.
The identity theft prevention program you adopt under this regulation would also require you to subject the documentation the customer provides to meet your CIP requirements (if you use documentary verification) to greater scrutiny - looking for other discrepancies (picture doesn't match individual, age doesn't jive, ID looks altered, etc.) and also look for the presence of other red flags that may indicate ID theft. In other words, CIP is just the first level - you obtain the four pieces of identifying information and you "verify identity" using documentary or nondocumentary means. The Red Flags regs ratchets things up a notch, requiring you to go the extra mile to attempt to detect identity fraud.
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