Posted By: wavewatcher
2 different IDs - 12/16/03 12:52 AM
We have a customer who has 2 identifications (drivers license and social security card) with 2 different names on them. One has the birth name, one has the preferred name. Which name can we use to open the account?
Posted By: Anonymous
Re: 2 different IDs - 12/16/03 11:58 AM
I think I would use the name "Refused". Can you think of any legitimate reason why a person would have two different driver's licenses and two different social security cards if they were on the up and up?
Posted By: wavewatcher
Re: 2 different IDs - 12/16/03 05:14 PM
the customer (long time) has a drivers license with the birth name and the ss# with the person's name who raised her. The customer has IDs in both names but not one showing all names - utilities in both names also.
Posted By: Terah2
Re: 2 different IDs - 12/16/03 07:58 PM
There still isn't a valid reason. Which one is her "Legal" name, and why would anyone choose to keep both unless they intended to hide something under one or the other?
Which SSN is she certifying to be her valid TIN?
Posted By: deppfan
Re: 2 different IDs - 12/16/03 08:23 PM
We had a similar situation several years ago when I was a teller. Turns out, the lady was receiving Social Security benefits under 3 names! Run the other direction and send an adverse action notice!!!
Posted By: Jokerman
Re: 2 different IDs - 12/16/03 08:52 PM
It may not be the case here, but I have seen a few instances where an individual would have a legal alias. Just a thought.
Posted By: Tisa
Re: 2 different IDs - 12/16/03 08:57 PM
Keep in mind that reporting 1099's with names not matching what's on the SSA's records may generate B-Notices...
Don't know if that helps you decide what name to use - or if you even want to open the account... but there it is.
Posted By: wavewatcher
Re: 2 different IDs - 12/17/03 05:16 AM
They are listed as AKAs in the credit report. This is an existing customer - we are CIPing all customers. We don't believe the customer is hiding anything; we have never received a B-notice from IRS with filing her 1099s. We just want to "get it right" with the new CIP.
Any other suggestions.
CIP rules require you to collect the legal name, and use either documents or non-documentary methods to verify what you have collected. The customer should tell you what their legal name is. Then, based on your senario, review and record a description of both of the documents the customer has presented. Since they have provided documents with conflicting information, you have a discrepancy that should be resolved to the extent you can form a reasonable belief you know this persons true identity.
This was an issue I had difficulty getting across to our employees in the beginning. Do not obtain the legal name from documents presented, obtain it from the customer and then use the documents to verify the legal name obtained from the customer. In your case, simply ask the customer which name is their legal name and go from there.
Posted By: wavewatcher
Re: 2 different IDs - 12/18/03 12:35 AM
We opened the account in the legal name; and also included the AKA.
