Answer:
If your customer was military and the expired ID, say a driver's license, was supported by a military ID, you might be OK, as the expiration on the driver's license is often extended by the state. That means because of dislocation, the license hasn't actually expired.
If that isn't the case, your CIP should require a current ID, and for good reason. Expired IDs can be unreliable. The actual owner, as one example, may have discarded it because it was expired. It may or may not have been doctored after that. The address may no longer be current, and that could complicate matters. The issuing authority may have opted not to renew the ID because of legal, employment or other issues. And last but by no means least, the CIP regulations at 31 CFR Part 103, Section 103.121 present the use of an unexpired government issued photo ID as a standard, and require that your bank include additional procedures for identity verification if you accept an expired document.
First published on BankersOnline.com 6/07/10
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