A customer of ours recently applied for a loan. The ID we had on file was out of date, and we needed an updated copy. This customer is a veteran and the US Government had his name incorrect on some of his paperwork-his first name and middle name was reversed on his Veteran's ID and on his last name, the last letter was different than what is should have been. He has been in court to try to get this situation resolved and has official court papers documenting the government's error and that it is being corrected. Meanwhile, his state driver's license expired and the DMV wouldn't issue him a new one until he received the final papers. He has received them but didn't get a updated licence before applying for the loan. We have a copy of his Veteran's ID (with incorrect name) and the court papers...would this suffice for CIP purposes until he brings in his new license to update our files? Sorry for such a long question...thanks in advance!!

I think it will depend on how strict your CIP is, and whether this sort of thing can be "reconciled with the documentary identification" used. You need to become confident the the guy is who he claims to be. A government SNAFU (I'll use a military acronym in honor of his veteran's status) should not be insurmountable, in my mind.

I'm rarely "convinced," but you have done it. Regardless, as John indicates, this is entirely about your CIP and what it directs you to do when there is a discrepancy between what you are told and what you are offered as verification.



Can he give you a license that reflects the name he offered you now?