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#2233301 - 03/19/20 04:10 PM Expired IDs during pandemic
Couples Offline
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Joined: Apr 2009
Posts: 280
The Igloo
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.

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BSA/AML/CIP/OFAC Forum
#2233339 - 03/19/20 08:34 PM Re: Expired IDs during pandemic Couples
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
Originally Posted by Couples
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.
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#2234067 - 04/01/20 05:09 PM Re: Expired IDs during pandemic Couples
EB, CAMS Offline
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EB, CAMS
Joined: Mar 2009
Posts: 133
flyover country
We have done some research on this issue. As it turns out, many states are extending temporary relief/extensions for expired ID's, essentially making them still valid for a certain period of time after this crisis is over.

We are allowing them for check cashing, new accounts, new loans, etc... if they meet the requirements for extension/exemption from their issuing state. Most states I've reviewed have said ID's that expire after March 1, 2020 until 60 days after the "safer at home" restrictions are lifted are to be considered still valid. We are doing education with our staff and documentation for all applicable accounts.
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#2247683 - 01/14/21 06:38 PM Re: Expired IDs during pandemic EB, CAMS
JennKK2 Offline
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Joined: Nov 2006
Posts: 262
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a very late follow-up but did you have your board make any statement to the fact you would be accepting expired ids?
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#2248192 - 01/26/21 06:59 PM Re: Expired IDs during pandemic Couples
JackieW Offline
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Joined: May 2019
Posts: 20
To add to The Frog Lady's comments, our specific state has extended the DL expiration to July 2021 for those that had an initial expiration date from March 2020 forward and considers them still valid. Because the state still considers the DL valid and not expired, no specific approval/reporting to the Board occurred.

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