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#139732 - 12/16/03 12:52 AM 2 different IDs
wavewatcher Offline
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wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
We have a customer who has 2 identifications (drivers license and social security card) with 2 different names on them. One has the birth name, one has the preferred name. Which name can we use to open the account?

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#139733 - 12/16/03 11:58 AM Re: 2 different IDs
Anonymous
Unregistered

I think I would use the name "Refused". Can you think of any legitimate reason why a person would have two different driver's licenses and two different social security cards if they were on the up and up?

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#139734 - 12/16/03 05:14 PM Re: 2 different IDs
wavewatcher Offline
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wavewatcher
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Hawaii
the customer (long time) has a drivers license with the birth name and the ss# with the person's name who raised her. The customer has IDs in both names but not one showing all names - utilities in both names also.

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#139735 - 12/16/03 07:58 PM Re: 2 different IDs
Terah2 Offline
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Terah2
Joined: Apr 2003
Posts: 107
There still isn't a valid reason. Which one is her "Legal" name, and why would anyone choose to keep both unless they intended to hide something under one or the other?
Which SSN is she certifying to be her valid TIN?
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#139736 - 12/16/03 08:01 PM Re: 2 different IDs
WildTurkey Offline
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WildTurkey
Joined: Jan 2003
Posts: 921
Down South, USA
Quote:

..... The customer has IDs in both names .....



I'm with Anonymous - refuse the account, and I'd file a SAR - it is completely unacceptable in 2003 for somebody to be using two different IDs. They should make their mind up who they are and then be confined to using an ID for that (one) name only.
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#139737 - 12/16/03 08:23 PM Re: 2 different IDs
deppfan Offline
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Joined: Dec 2000
Posts: 5,184
All over the map.
We had a similar situation several years ago when I was a teller. Turns out, the lady was receiving Social Security benefits under 3 names! Run the other direction and send an adverse action notice!!!
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#139738 - 12/16/03 08:52 PM Re: 2 different IDs
Jokerman Offline
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Joined: Nov 2003
Posts: 12,846

It may not be the case here, but I have seen a few instances where an individual would have a legal alias. Just a thought.

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#139739 - 12/16/03 08:57 PM Re: 2 different IDs
Tisa Offline
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Tisa
Joined: Jun 2003
Posts: 938
Do you know the way to ...
Keep in mind that reporting 1099's with names not matching what's on the SSA's records may generate B-Notices...

Don't know if that helps you decide what name to use - or if you even want to open the account... but there it is.
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#139740 - 12/17/03 05:16 AM Re: 2 different IDs
wavewatcher Offline
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wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
They are listed as AKAs in the credit report. This is an existing customer - we are CIPing all customers. We don't believe the customer is hiding anything; we have never received a B-notice from IRS with filing her 1099s. We just want to "get it right" with the new CIP.

Any other suggestions.

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#139741 - 12/17/03 04:45 PM Re: 2 different IDs
LiL Bit Moore Offline
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LiL Bit Moore
Joined: Nov 2002
Posts: 624
Texas
CIP rules require you to collect the legal name, and use either documents or non-documentary methods to verify what you have collected. The customer should tell you what their legal name is. Then, based on your senario, review and record a description of both of the documents the customer has presented. Since they have provided documents with conflicting information, you have a discrepancy that should be resolved to the extent you can form a reasonable belief you know this persons true identity.

This was an issue I had difficulty getting across to our employees in the beginning. Do not obtain the legal name from documents presented, obtain it from the customer and then use the documents to verify the legal name obtained from the customer. In your case, simply ask the customer which name is their legal name and go from there.
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#139742 - 12/18/03 12:35 AM Re: 2 different IDs
wavewatcher Offline
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wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
We opened the account in the legal name; and also included the AKA.

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