Verification of Identity (VOI) can be challenging when different forms of identification contain variations of the same name but belong to one and the same person. Another issue that can arise is where a client has a different appearance in two forms of identification that might lead a reasonable person to believe that they are photographs of two different people. These photographs might also differ to the current appearance of the client.
The following approach has been provided to AIC VIC by a member of our committee to help members navigate VOI.
Scenario 1: Variation of client name on identification documents
Australian Passport: John Victor Citizen
Driver’s Licence: Victor John Citizen
Medicare Card: John V Citizen
- The client has provided their Australian Passport and Medicare Card for the purposes of a VOI.
- You have conducted a VOI check with a third-party provider, which has been rejected and have been provided with a VOI report.
- The client then provides their Australian Passport and Driver’s Licence for the purposes of conducting a further VOI check with a third-party provider, which is completed but rejected. You are provided with a second VOI report, which reveals that:
- the client’s first and middle names are reversed when comparing the Australian Passport and the Driver’s Licence,
- the client’s photograph on the Australian Passport and Driver’s Licence match, and
- signatures match across documents and with what is saved on the client’s file.
- The client does not have two photo identification documents with his name in the same order.
What should you do next? What is the best approach?
- Call to client to discuss the issues arising from the VOI reports. You should:
- draw your client’s attention to the fact that he does not have two forms of identification where his name is in the same order.
- inform your client that a one and the same statutory declaration is required to proceed.
- Send a blank statutory declaration to the client for completion together with a witness list.
- Ensure receipt of a properly completed, signed & witnessed statutory declaration from the client.
- Verify the client’s signature.
- If the first VOI check is rejected, you must always complete an additional VOI check and ask the client to provide additional identification documentation.
- A Conveyancer can reasonably satisfy themselves and approve the VOI with a supporting statutory declaration.
Scenario 2: The client’s actual appearance is different to his/her identification documents
In this scenario, you have noted a significant difference in appearance between the identification documentation and the client’s actual appearance. The client has provided their Australian Passport and Driver’s Licence. The identification documents have passed the third-party verification check.
What should you do next? What is the best approach?
- Check that the signature on the VOI matches against the documents you have on file containing the client’s known signature. Assume in this scenario, that the signatures match.
- Have another staff member check the VOI report for a second opinion.
- Formulate a strategy for approaching this situation using the suggestions provided below and seek approval from the management team.
- Contact the client on their known number to discuss the change in appearance and ask the client if they have any identification documentation with a current photograph.
- If the client can provide a reasonable explanation for the change in appearance, which is to your satisfaction (e.g., significant weight loss following lifestyle change) but does not have any further identification documentation, this should be sufficient to determine that VOI has been successfully completed.
- Ensure that you pass on this explanation to the management team and seek their approval that VOI has been completed. The basis for VOI being completed in this scenario is that there is a satisfactory explanation for the change in appearance, signatures match and identification documents have passed the VOI check.
- If the client can’t offer a reasonable explanation and you have suspicions, raise this with the management team internally to determine the best course of action.