Our document list is broken down into primary and secondary acceptable documents, as I'm sure many of yours are. As I understand a primary document should be govt issued, contain a photo or similar safeguard, contain an expiration date, and indicate the place of issuance. Based on this criteria could a fire arm permit be considered a primary document?

I've heard it said that firearm permits are some of the hardest pieces of ID to come by - so I'm betting they are good ones to accept. As far as I know, they meet the qualifications you listed. I think it's up to your bank and it's CIP risk assessment as to whether you'll accept them as primary or secondary.

Leslie G. is right - your bank must set up the parameters as to what you consider to be primary identification. I have recommended that the only primary id is a drivers license with photo from the state in which the bank is located. Every other government issued photo ID is secondary identification. My reasoning behind this is that you must design your CIP with the thought in mind that your weakest CSR is going to have to carry out the CIP. They are on the front lines. I don't think I'm that sheltered up here in New Hampshire, but I don't have any idea what other states drivers license look like or military ids or passports. To me they are secondary in the sense that collaborating ID is required for acceptance as positive ID. If I don't know what neighboring states license look like I know a lot of good CSRs that don't either.

Lil Bit,
Clearly, a concealed carry or gun permit would be a good form of secondary identification. Elevating it to the level of primary identification should be a function of how difficult it is to obtain in that state. In both your home state and mine, it is considerably more difficult to obtain a gun permit than a drivers license; e.g. background checks and classroom instruction are required.

This web site contains links to information on the requirements for gun permits for all states.

You may have a point, Tom. However in the rest of NH, North of Concord it may be a different story. I'm not sure how many of the Mass minions come to banks on their trek North. The border towns may know Mass licenses or Vermont in some cases. My point is that primary ID can only be a document that is known to the person to whom it is presented.

I have a question.

Does the primary document have to have an expiration date? I know it has to be unexpired, but when the rule talks about recording information it says "For an individual, unexpired government- issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport".

Then later the rule says you have to keep "A description of any document that was relied on under paragraph (b)(2)(ii)(A) of this section noting the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date".

Most carry permits and gun licenses don't have expiration dates, so I guess it makes a difference. I went to the site Ken so kindly provided and looked to make sure. But it seems awfully strange to say that a driver's license is more valid identification than a carry permit with a person's photograph and fingerprints, especially given that a background investigation is conducted on every applicant.

It's probably about the best documentary ID available from the viewpoint of really knowing who the person is. They probably are forged less, too!

Kathy

Your answer seems to be in the language that says:

Quote:

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the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date".

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The "if any" language would seem to modify both "date of issuance" and "expiration date". The regulation specifically mentions as examples some types of documents that will not ordinarily have expiration dates, such as articles of incorporation or partnership agreements.

Funny how we all look at these things from a different perspective. We do consider both the military id and passport as primary ids in addition to our state's drivers license. If you want to talk about an id hard to get lets talk the military id! It involves enlsiting for service or having a primary family member who is in the service. Although there can be fake passports we still find them to be a safe id and being in a metro area (Chicago) for a whole lot of years, I can say I have not (yet) seen a fake US Passport. Of course we won't take other country's passports nor will we take other state's driver's licenses.
As far as a firearm's id, I look at it this way. Whether it's hard to get or not, why would you open an account for someone who's BEST id is THAT one??? Frankly, I'd be a little worried if that's all someone could toss my way!!
The bottom line is all id can be forged ... your choice of id should include those you are most familiar. I just attended a good seminar held by our Secretary of State department showing all the ways the IL Driver's License has been counterfeited and how to tell a real from a fake. It was valuable information and you might want to check with your own state's DMV to see if they offer this training also.

Mr. Virr, my driver's license was originally obtained in 1959. I went to the police station, filled out an application, paid my fee, took the eye exam and passed a written and driving test. I received the license immediately. There was no photo of me on the license. I did not have to prove who I was, and I provided no form of identification to the examiner. (At that age I could not have provided any identification if he had asked for it.) Five years later the license, along with my billfold went through the wash, and was reduced a course powder. A motor vehicle employee who did not know me, only asked to see the old license, which was in powder form, and then replaced it. Years later the license was stolen and again replaced without question or proof of ID. (They did verify by telephone that a driver license was issued to someone bearing my name and that it was valid.) My current license is a renewal of that poorly documented driver’s license. My social security card was obtained from the local post office when I was about 16. I signed a form requesting the Social Security Number and was given a Social Security Card. No ID was requested, nor was ID provided, not even the poorly documented driver’s license. Would you consider this as the primary proof positive that I am who I say I am? It seems the government, along with banks and other business place a considerable amount of faith in the aforementioned documents. In fact all other forms identification I now carry are based on those two documents.

Anon raises the point that turns the whole thing into an exercise: We are totally dependent on the validity of the intitial identification, even if we use biometrics. Once the "breeder document" is received, all others flow from it; the Florida banker who accepts and authenticates a Florida drivers license is sunk if the Florida license was obtained using a fraudulent Oklahoma license.

Majority of the folks are law abiding so we should not get too paranoid and question the authenticity of every Govt. issued ID to the extent that we can't open accounts anymore.

I am sure most of you have the electronic devise (we call it Demomate), which scans State issued DL’s and prints out the information on the strip at the back which can be matched to the information on the face the ID. If it matches , there is no reason to dig further as to the validity of when it was issued.

On a lighter note, when asked to identify himself, a man looked into the mirror and said, "That's me!"