Hello. We are having a discussion regarding names and how loan documents should be drafted. A customer comes in and they apply as P. L. Jones and sign the application as such. Our CIP on our core system also says P. L. Jones. Their drivers license says Paul L. Jones. Should we be drafting the documents and updating our system according to how the drivers license states since that is an identity verification tool or should we be drafting them how the applicant applied? I believe we closed the loan as Paul L Jones and the customer signed as P L Jones.

Another example being what if someone applies as Donna Sue Jones should we be drafting the documents as stated or abbreviating the middle name to just S even if the drivers license says Donna Sue? (I can tell you that Ohio is now putting full middle names on drivers license where previously it was just a middle initial) I don't feel we should be questioning every application as to whether the name on the application is accurate or legal if it matches to the drivers license when presented.

Is there something in the regulation that states to this process and how it should be done?

This discussion is for the loan documents outside of the mortgage or having title work. We do put the name on the mortgage to match the vesting in those situations. Thank you.

This is not a regulatory issue, but one of contract law that would be based on the enforceability of contracts under State and case law in your jurisdiction.

This really needs to be asked of your legal counsel.