Verifying the Identity of Clients Who DON’T have Photo ID
There are some clients who do NOT have valid government issued photo ID such as a driver’s license or passport. For example, an elderly client selling the family home or their interest in the family business.
So, how do you verify the ID of someone who can’t flash you their government issued photo ID? You can use two pieces of information (‘trusted documents’) from a reliable source.
This two-piece method requires some advance planning because the two trusted documents must be original – not a photocopy or electronic image like a digital photograph, screen capture or scanned copy. Most clients will not be carrying these documents in their wallets and will need to be instructed to either bring them with them, deliver or snail mail them to you.
How Does this Two-Piece Information/Trusted Document Method Work?
What is a Reliable Source?
The two trusted documents have to come from a reliable source. Federal, provincial or municipal governments, crown corporations, utilities (hydro, gas, telecommunications companies) or financial institutions all qualify as a “reliable source.”
What Information MUST the Two Trusted Documents from the Reliable Source Include?
The trusted documents must include:
- the client’s name and address; or
- the client’s name and date of birth; or
- information that contains the client’s name or confirms they have a deposit account or credit card or other loan with a financial institution.
Examples of acceptable trusted documents include:
- CPP statement
- vehicle registration
- municipal property tax assessment
- CRA issued communication including Notice of Assessment, GST Credit Statement, T4
- utility bills
- foreign travel visa
- record of employment
- government benefits statement
- birth certificate
- permanent resident card
- citizenship certificate
- marriage certificate
- credit card statement
- mortgage statement
- bank statement
- registered investment account statements (e.g. RRSP, TFSA or RRIF)
- insurance documents (e.g. home, auto or life)*
MIX – Don’t Match!
You must have two trusted documents from two different reliable sources. This means you can’t use the client’s October and November TD Visa statements. But you could use the October TD Visa statement and an October President’s Choice Financial Master Card statement. And in case you were wondering, the reliable source is the issuer of the information – like the financial institution or Hydro or MPI – not your client.
You Need to See the Original
The two trusted documents must be original – not a photocopy or electronic image like a digital photograph, screen capture or scanned copy.
If your client gets their information from reliable sources electronically, they can show them to you on their mobile phone or they can log into their account at your office. You can look at the document the reliable source has emailed to them or see the statement on the reliable source’s mobile app or secure website, looking over the client’s shoulder. Now that you’ve seen the original, the client can then transmit that trusted document to you or you can take a screen shot or even a cellphone photo of it for your file.
Using Information from a Reliable Source When You are NOT Meeting with the Client in Person.
If you are not meeting with the client in person and the client has the two trusted documents in a hard copy original format, they can snail mail or deliver the original trusted documents to you so you can copy it and mail it back to them.
If the client receives trusted documents from a reliable source electronically, the client can try to email you the document received from the reliable source or to send you a link to the document on the issuer’s website or app. You may not be able to open those documents because access to them often requires your client’s log-in and password. If you can’t open the documents, you may have to arrange an in-person visit by you or through an agent. This might delay the required verification, so plan ahead.
For more information visit the Anti-Money Laundering Resource Library:
