CIP and Expired Driver’s License during COVID
Due to the COVID-19 pandemic and the fact that many government offices were closed, most states implemented emergency proclamations allowing a grace period for renewing driver’s licenses that expired after March 13, 2020. Not all drivers are eligible to renew their driver’s license online and with offices closed to walk-in appointments, that creates a problem.
Why is this “compliance” news?
Mainly because this could directly impact your Customer Identification Program (CIP). If a new customer comes in to open an account and they provide an expired driver’s license, several questions arise. Is it really expired? If so, are you prepared to handle this from a CIP, identity verification standpoint? Did your state implement a grace period for license renewal? If so, what are the expiration and renewal time periods and when does any grace period end?
The best resource to determine this information is your state’s Department of Motor Vehicle website. Look for updates on driver’s license renewals during the COVID-19 pandemic. You will need to decide if you will accept expired licenses that fall under the state’s grace period or maybe you will require another form of documentation to verify identity? Depending on your decision, you may need to adjust your current CIP procedures with this temporary change. If/when accepting a driver’s license with an expiration date after March 13, 2020, be sure to document not only the expiration date, but also the “extended through” date to evidence your reliance on the state-implemented grace period. This information should be retained with the CIP identity verification documentation.
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Published
2020/08/19
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!