Is anyone contemplating accepting expired IDs (mainly drivers licenses) in light of the pandemic and the possibility that customers may not want to or can't go to a DMV? This would be only for maintenance on existing accounts and opening new accounts for existing customers.
We have had a question from our retail area. I'm afraid that it may lead to additional follow up. If we would do this, we would only do it if the license expired after March 1 (Taking the date from the news that the TSA is now accepting expired DLs after 3/1.)
If the customer can come up with two other acceptable forms of ID, then it wouldn't be an issue. We could perform maintenance and open accounts for new customers.
I'm trying to anticipate any downfalls to performing maintenance or opening new accounts for existing customers with an expired ID.
All and any thoughts are appreciated.
Much of the guidance coming from regulators this week centers around taking additional actions to be consumer-friendly and understanding during this crisis. Given that your limiting these exceptions to existing customers, there should be minimal concerns. The only thing I'd recommend is to track those exceptions and follow-up with the customers when life normalizes.
From a pure technical standpoint, they're exempt from CIP requirements anyhow. Although the spirit of the CDD rule dictates that you'd obtain the updated license, it's not as much of an explicit requirement as CIP. Some from that vantage point, you have some wiggle room.