Are we going to be able to do ChexSystems checks on beneficial owners in order to verify their identity?

If ChexSystems will provide the information you need without its report being a consumer report as defined in the FCRA, yes. Otherwise, no, because you would need the BOs' written permission to do so.

How are most banks going to be verifying identities?

By obtaining a photocopy of the BO ID, based on our existing ID requirements. We will use the eFunds ID Verification component for the OFAC screening.

And we can't use eFunds to do ID checks either, correct? Is it the same as ChexSystems?

eFunds IDV and Chex Systems are products of the same vendor, and often sold together, but they are not the same thing.

Chex is a consumer report, and was never intended as a CIP tool. IDV is a non-documentary verification service that was specifically designed with CIP requirements in mind.

It's too early for anyone to claim he or she knows what "most" banks are going to do. The preamble to the CDD regulation indicates banks can use photocopies of identification. The preamble to the CIP regulation indicated banks are not required to verify all four pieces of information, just enough to establish a reasonable belief of the customer's identity.

There is no way to legally verify the name/TIN combination of a beneficial owner, but there is probably no need to either. Don't make this harder than it needs to be. Go with a photocopy of the identification and be done with it.

We are planning on using IDV as our non-documentary verification of Beneficial Owners.

We are currently checking TINs against LexisNexis to confirm that the SSN given by the UBO on the form matches the name - it's a quick check and quick save of the screen to show our work. That's as far as we are going with verification. If it does not match, we reach back out to the business line and let them know that the UBO did not provide accurate information and they need to follow-up and get it.

Unless a bank is querying the IRS data base, that is simply impossible; there is no commercial product that can verify a name/SSN combination. As Social Security began randomizing the assignment of SSNs in 2011, the vendors' ability to even say when and where the number was issued is declining at a steady rate. Yet, the vendors keep selling the same old ____.

I agree with Ken. If the BO is not a signer on the account, just request a copy of their identification, document it and be done with it.