Our bank's CIP Procedure requires that a customer provide one of the following as primary identification: drivers license, state identification card, passport, military id, cedular card, or green card. We also require one form of secordary identification that may consist of an additional form primary id, of the previous items listed, or something from our secondary list.

With that being said: a customer has presented a drivers license and a state identification card to comply with our CIP requirement. The question is now whether this is actually acceptable as 2 forms of ID because both the drivers license and the state id have the same identification number? They were issued on different dates and also have different expiration dates. I did verify that the drviers license is valid.

Thanks for any opinion or direction in this matter.

We consider a DL and ID card as one form of identification. I have a footnote in my CIP procedures that indicate that another form of identification is required in these instances.

Per Dolly's observation, your list of acceptable primary ID might be written as:

* Passport
* Military identification
* State drivers license or state ID card
* Cedular card
* Green card

That should be enough to imply that it's an "either or" situation. Regardless of how your CIP is worded, I don't think you can have a valid driver's license and a valid state ID card from two different states at the same time, even if you have a residence in both states. This individual only has one legal residence.

The drivers license and the state id and both from the state of FL. I was able to verify that the license is valid, but could not verify the state id. Thank you for your input!

My question would be why do they have both? A State ID card is normally for people who do not have a driver's license.

In this particular case I believe they had their drivers license issued later in life.

In follow up I did contact the FL Department of Motor Vehicles on this issue and they stated that it is acceptable for an individual to be issued both a license and a state id card, and verified that the number would be the same.

This is really a matter of interpreting your CIP policy since the CIP regulation doesn't even require one ID document, much less two. I think you need to look to the language that your CIP policy uses for setting the boundaries of what you will accept.

It is possible to have both a DL and State ID card here in Pennsylvania. If you lose your DL for Violations/Points/DUI/Underage Drinking/etc, the State advises you to get a PA ID Card for the time that you are without your license. For the 21-30 Age Group, it provides ID verification for entering a bar/club, for example. When they get their DL back, they would still have the PA ID Card.

As the person who responsible for CIP at our bank, I would consider them interchangeable and would want to see another form of identification.

My son has a state ID card and will (eventually) get a driver's license. (Watch out y'all.) He'd have both as I don't believe Texas requires one to be surrendered for the other. Rarely, but it does happen in some secured areas, two separate photo IDs are required. So there can be a need for both.

We are beginning to get voter registration cards presented as ID for those that do not have DL. These of course are issued by the state (GA) and are a picture ID but there is not signature or expiration date.
For CIP would this considered a type of government issued ID and acceptable as such? Would it be prudent to get another form of ID as well?

I will disagree because how can you identify someone without a document? You certainly cannot take their word for it and you want to use a document that they obtained by supplying valid information to certify their identity. How to you establish identity if you do not require evidence?

The regulation allows you to use documentary, non-documentary, or a combination of both. If your CIP allows it, you could take the information provided by the customer (name, address, TIN, and DOB) and compare it to information you get from a credit report, ChexSystems, reference checks, public records, etc. You do not have to use ID documents unless your CIP requires it.

ledfoot - we accept voter registration cards but only as a second form of ID and only if the county and district matches the address the applicant is using to open the account.

We do not use it as primary ID even though it is government issued.

Hope that helps!

trail hiker: Deena said it pretty well. I didn't say to take their word for it and I didn't say no evidence. Nondocumentary systems are available and can be used in addition to or in place of documents under the CIP regulations.

Obviously, if your program requires documents, that must be followed.

We require 1 piece of primary id. It can be a DL, State ID, a military ID, a military dependent ID, or a foreign passport. They all have a picture, a signature, and an expiration date.

BTW, no has used either of the military ID types.

I see your point but I view the FFIEC statement that "the rule reflects the federal banking agencies' expectations that banks will review an unexpired governement issued form of identification from most customers" to mean that it would be better if the non-documentary method was for those customers that would fall outside the "norm" such as an elderly person without a drivers license or passport, etc.
However, I am not a BSA Officer nor am I a BSA expert!
I do find it peculiar that if you use documents you should have one that provides a picture and evidence of a customers nationality but you are not expected to have that with non-documentary methods. Which again, makes me think non-documentary would be most appropriate for unusual circumstances.