Compliance Blog

May 27, 2020
Categories: BSA BSA

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.

Credit unions in states where the validity of identification documents was extended are able to continue to accept these documents. For examination purposes, credit unions may want to document if this is the case. In contrast, credit unions in states where validity of these documents has not been extended may want to evaluate whether any supplemental documentary methods (i.e. passports, identification cards, etc.) can be used to identify potential members, as well as whether documenting any decisions or policy exceptions may be appropriate. In absence of relief or guidance, any flexibilities may ultimately be a business decision for credit unions to make.  

There is a relevant discussion in our network - the NAFCU Compliance, Risk & BSA Network. You may want to join so you can participate in the conversation. 

What About Passports? In Case You Were Wondering… COVID-19 has also had an impact on U.S. Passport operations and renewals. Validity for passports has not being extended by the federal government. According to the related FAQs issued by the U.S. Department of State regarding this particular concern, “unless [individuals] have a life-or-death emergency” - which is defined as a “serious illnesses, injuries, or deaths of immediate family that require travel outside the United States within 72 hours (3 days)”- persons are encouraged to “wait to apply for or renew passports or [they] will experience significant delays of several months”.

In addition, due to COVID-19 the Department of Homeland Security (DHS) extended the REAL ID deadline by one year until October 1, 2021. Therefore, REAL ID will not be enforced at airports later this year. 


Upcoming Webinar:  Diversity, Equity and Inclusion in Credit Unions

NAFCU is hosting a Diversity, Equity and Inclusion (DEI) Webinar on Friday, May 29, 2020. You can read about this webinar and register here. Speakers include: Monica H. Davy, Director, Office Minority & Women Inclusion, NCUA, Charlotte Ducksworth, Board Chair, DC Federal Credit Union and Lynette W. Smith, President/CEO, TruEnergy Federal Credit Union. You can also learn more about DEI in this NAFCU Compliance Blog Post.