CIP - Valid ID Number
Answer by John Burnett, BOL Guru Guru Bios
Question: It’s my understanding that for CIP of a US citizen a driver’s license number is not a valid ID number, but a that a TIN is required as an ID number, correct? If so, where can I find the citation/rule?
Answer: You'll find it deep in the CIP regulation. Specifically, it's at 31 CFR 103, section 103.121(b)(2)(i)(A)(4)(1), which reads: (4) Identification number, which shall be: (i) For a U.S. person, a taxpayer identification number;
The driver's license may be a documentary source of verification of the customer's identity, and you should record its number, issue and expiration dates and name of the issuing state as part of the record of how you verified the customer's identity, but the ID number that is the fourth item of identity that the customer must supply (the others are name, street address and date of birth) must be a TIN if the customer is a U.S. person. For the purposes of this section of the regulation, "U.S. person" means a U.S. citizen or an entity that is established or organized under the laws of a State or the United States.
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