I didn't have a good answer for this yesterday. I was told we very often do not get an ID with a current address. This is not limited to the military, but all people who do not pay a fee to change the address on their driver's license.

If that address is incorrect, my recommendation was to get something else to verify the address, lease agreement, utility bill, etc. I was asked, why if we don't have to verify all the data we get at opening such as a DOB, why do we have to validate the stated address? "Cuz we do" wasn't accepted.

This data seems important enough that they should have some verification of the address they say they reside at now. In my mind this isn't a verification on our part, but on the customers to substantiate the info they are providing. Is this a reasonable explanation?

I have edited the post so the title wouldn't be too confusing with one by the same name.

I agree Andy, and I think your explanation is very reasonable. While we certainly shouldn't decline opening the account just because the address doesn't match (takes a while to get those things changed sometimes), we should be provided with some verification of the correct address. We use that address often, and we need to know that it's accurate.

Also, in Texas, we should probably warn them what happens if the friendly DPS officer stops them and figures out they haven't updated their license!!

Well, it seems reasonable to me. But if Andy said the moon was blue, except on Tuesdays when it was purple, I would probably assume I've been color-blind all my life.

I was looking at the required items and record-keeping provisions. Except for military personnel, the customer's physical address(or a contact address) is one of the things that must be obtained under the rules, and so is a resolution of any substantive discrepancy:

(D) A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.

So Andy's suggestion of requiring another document would be to resolve a substantive discrepancy, right?

Kathy

You talk about the moon as though it isn't blue. How do you think the song, Blue Moon, was inspired.

The resolution of discrepancies is right on. But without the need for photocopies of IDs, in this case, you wouldn't really know there was a discrepancy to be resolved.

Well,how you handle this may be state specific. I have friend that moved recently she called the CA DMV and they told her they would record her address change once she submitted it, but that she should just carry around a piece of paper with her new address on it until her license was up for renewal. They did NOT encourage her to come in a get a new license. She's carrying around a little piece of paper.

We are verifying addresses in a old fashion way - we send thank you cards - in addition to using Chex system's ID Verification tool.

While it's not perfect, I can't think of another way to do it, if you aren't required by law to change you DL.

When I moved and called DMV, I was told I can only get a new license with my current address IF I reported my license as lost or stolen. The person at DMV told me that the Driver's License is NOT intended to be an identification document, it is simply a license to operate a motor vehicle.

So I also have a little slip of paper that I carry with my license. Hopefully, I won't be opening any new bank accounts for the next two years.

Good points. Those sound like weird rules, but possibly cost effective ones. I guess if you don't like the rules, change the politicians.

Didn't y'all once say that a CA. DL wasn't intended to be used as a form of ID? It is like a SSAN being the property of the SSA and not to be used for other purposes.

I also see issues with drivers licenses. When I was in the military police I recall DLs were allowed to expire and a military exemption allowed it to be seen as valid and unexpired when you were out of state. But I don't know now if that applies to all states or not.

Yeah, California DMV doesn't stand behind their identification of the person they issue the drivers licenses to. Only that the person they issued the license to is qualified to drive. (And sometimes that's questionable...)

Think about it -- all you need to get a drivers license when you're 16 is a birth certificate, a certification that you've passed Driver's Ed, and a passing score on the written and road tests. Nowhere do they make you swear that the name on the birth certificate is yours.

Kinda scary, seeing as how just about everyone takes them as formal identification.

Passports aren't much better - bring them a birth certificate and a 2x2 photo, and they give you a US Passport! Although, they do make you swear that the statements on your application are true... (and nobody who was trying to get a fake ID would ever lie... )

I was under the impression that you only had to record the resolution. I don't think it is necessary to have the customer provide a copy of another document (utility bill) to prove they now have a new address. I would document the reason for the discrepancy (bought house, job transfer etc.) and send a thank you note. If the thank you note comes back, then there is more to do.

In addition to thank you cards/calls, we generally try to set up new accounts so they "cycle" on the next available date. Then a statement would be cut within a few days and any returns for address on new accounts can be researched further.

If the customer's documentation includes information that is inconsistent with the information the customer provided, I do not see any suggestion that you can only reconcile that by obtaining another document. You should still be able to make a risk based decision to verify the information using documentary or nondocumentary methods. For example, if the DL address is inconsistent, you could opt to verify the address using nondocumentary means; e.g. a credit report.

However, I cringe at the suggestion that, "We don't have to verify everything" is a valid response to how the bank resolved a discrepancy. That's ignoring it, not resolving it.

It appears contact personnel might need to know a bit about state laws regarding when customers are required to update their address with DMV and the appropriate methods. Texas apparently allows drivers to do it online ($11 fee) and mails them a new license several weeks later, but the web site does not indicate how soon after moving the driver must notify the state. Kentucky requires the driver notify the state of the address change within ten days, but she must go to a license branch, pay a $6 fee and receive a duplicate license.

From my read, 521.054 says a Texan (and wannabes) has 30 days to make this address change. This cite and similar ones for your state may be helpful in the application of your procedures.

I have also discussed the military exception allowing an expired DL to be treated as valid. It turns out a form is required for this. In Texas it is an LI-9, other states may have similar requirements. This form may be needed to resolve the discrepancy of it being expired.

I also wondered if having an incorrect address would render the DL invalid for CIP. But as some of us refer to "valid" as being unexpired, CIP uses the term "unexpired".