The mortgage servicing rules state we must confirm the identity of a potential/confirmed successor in interest. What are the steps others are taking and how in-depth are you going to confirm identity?

We're crafting a chart with a two-step process for our Loan Servicing area to follow when they receive docs from a potential SII. Step 1 will be to confirm the SII's identity with a copy of a state issued driver's license or state issued ID. Step 2 will be to confirm the SII's ownership interest in the property by reviewing the documents applicable to the type of transfer. For example, our draft procedure says for transfer by divorce we would request and review a divorce decree, court order transferring the property, and recoded deed. We're debating if we're going too in-depth for the confirmation of ownership interest step.

How do you identify a potential successor who is not in your footprint? For example, we are a local community bank in a western state. The borrower dies, the daughter lives in Florida and is the successor in interest. How do you properly identify the daughter - she cannot come into the branch with her state-issued ID. We talked about doing it electronically through a Doc-u-Sign process, but what if the successor does not have the ability to do that? (Perhaps an older person who is not computer savvy)?

How about an "Affidavit of Identity" or "Notarized Identify Verification" form whereby the successor affirms name, address, etc. and "under penalty of perjury" states that the information is correct. And the Notarization says that the person appeared and "proved on the basis of satisfactory evidence" to be the person?

We would like to obtain security questions - perhaps we can add those to the form as well?