Your policy probably says you are not required to perform CIP on an existing customer, but I doubt that it prohibits you from doing it.There are only two choices:
* perform CIP (including verifying the name/TIN combination) or
* don't.
I'm not citing you to a rule, just saying that I would want verification records to match to the name shown on the loan documents, in large part because I would not want to take the time explaining the situation to any third party reviewer.
P.S. As long as your applicant did not change his last name, the name and SSN will match for IRS purposes, the unknown is whether the credit bureau has gotten the message. You are in a position to help this individual make certain that everything that needs to be done has been done.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.