Expired identification documents and CIP during COVID-19

A month ago I blogged about BSA/AML compliance during the COVID-19 pandemic. Today’s post covers one of the most frequently asked questions the compliance team at NAFCU has received the last couple of weeks: Can a Credit Union Accept an Expired ID for Customer Identification Procedures (CIP) Purposes During the Pandemic?

Some Background. Many states have closed their Department of Motor Vehicles (DMV) or Motor Vehicle Administration (MVA) offices due to the current national emergency amid the COVID-19 pandemic. While some states have kept their DMA/MVA offices open, many are only offering “critical services,” which do not include license and registration renewals. Also, only a handful of states are offering online renewals. These actions were deemed necessary by the states to mitigate the spread of COVID-19, protect the public health, and provide essential protections to vulnerable persons, but it has resulted in some individuals being unable to timely renew their license or registration. As a result, credit unions have seen an influx of expired drivers’ licenses and IDs when opening new memberships and accounts.

What Can Credit Unions Do?; Are there any Flexibilities? Thankfully, many state governors have issued orders extending the validity of identification documents to facilitate the mobility of their citizens during this crisis, while maintaining appropriate social distancing. Most of these orders temporarily extend not only the validity of drivers’ licenses, but also of certain operator’s and chauffeur’s licenses, state identifications, and vehicle registrations to ensure continuity of auto insurance coverage. The duration and scope of the extensions vary from state to state and go anywhere from 30 days from the original expiration day (shortest) to 30 days after the State of Emergency ends, whenever that is, or “until further notice” (longest). Credit unions may want to check their state orders and contact local counsel to see if the governors in their states have issued an order providing some relief or flexibility in this respect.


continue reading »