Our bank's practice is to enter into our core system the person's name exactly as it appears on their driver's license.

If the customer's middle initial is something different than what is on the license, is that a discrepancy that must be resolved under CIP?

For example, the customer's license says "Jane H. Doe" but Jane's legal name is actually "Jane J. Doe".

This question came up because Jane wants Jane J. Doe entered in our system but the employee refused (citing CIP) because the license shows Jane H. Doe. We have the ability to enter any name we choose in a nickname field but that didn't satisfy the customer.

Did the customer offer an explanation? Is one initial from her actual given middle name, and the other from her maiden name, for example? Oddities like that sometimes can result in mistakes at the DMV.

I've just found out it was her full maiden name listed on the license (in the middle name field).

My driver's license is exactly like that, my first name, my full maiden name is in the "middle name" field and my married name is last. I did it that way on purpose after I got married to help with checks and such that came with my maiden name. I also did it because I hate my middle name and never want to use it or the initial. In my opinion (and dependant upon your CIP) a middle initial difference shouldn't be a big issue as long were you able to form a reasonable belief of their identity from the information you obtained and from the documents you reviewed. Plus naming conventions differ in different areas, some people have 2 middle names, etc. Anyone else disagree?

ItNeverEnds - you bring up a good point when you mentioned "dependant upon your CIP". Our CIP is written so that we obtain name, address, identification number, etc. and for an individual, we use a combination of documenatary and non-documentary verification.

We've not said in our CIP policy that the "middle" name entered into the core system has to match the license exactly....I believe some employees have made an assumption that it must. On last names, it has been our practice that if the driver's license differs to what they want on the account (maybe just got married), then the employee obtains some type of document with the correct name on it. This is the first time that the issue of the "middle" name has come up.

Is this the type of situation that should be spelled out in the bank's CIP policy? If so, what other types of situations would you spell out? I guess I'm worried that if I try to come up with all the possible scenarios that might occur, I'm sure to miss something.

Any input is appreciated.

It would depend on how your CIP program defines "substantive discrepancy". All substantive discrepancies have to be resolved and the information used to resolve a substantive discrepancy has to be maintained for 5 years.