FINTRAC's Guideline to Ascertain Identity

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http://www.fintrac-canafe.gc.ca/publications/guide/guide11/11-eng.asp

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Single process methods

Government-issued photo identification method

How do I use a photo identification document to ascertain the identity of my client?

You can rely on valid, current and original photo identification issued by a federal, provincial or territorial government to ascertain client identity. You may accept a foreign photo identification document if it is equivalent to a Canadian photo identification document listed in this guideline.   Photo identification documents issued by a municipal government, Canadian or foreign, are not acceptable. 

You must view the original document while in the presence of your client in order to compare your client with their photo. 

The photo identification document must:

indicate the client's name

have a photo of the client

have a unique identifier number

It is not acceptable to view photo identification online, through a video conference or through any virtual type of application.  You cannot accept a copy or a digitally scanned image of the photo identification.

Credit file method

How do I use the credit file method to ascertain the identity of my client?

You can ascertain the identity of a client by referring to a Canadian credit file that has been in existence for at least three years.  To be acceptable, the credit file details must match the name, date of birth and address provided by the client.  If any of the information does not match, you will need to use another method to ascertain client identity.

Complete credit files provide ratings on individuals to assess their ability to repay loans; however, it is possible to request a credit file to confirm a client's identifying information that does not include a credit assessment. You do not need a credit assessment to ascertain client identity.  Equifax Canada and TransUnion Canada are Canadian credit bureaus that provide credit file information for identification purposes.

A client cannot provide you with a copy of their credit file. You must obtain the information directly from a Canadian credit bureau. It is acceptable, however, to use an automated system to match your client's information with credit file information. You may also rely on a third party vendor that can provide you with an original and valid Canadian credit file. A third party vendor is an entity that is authorized by a Canadian credit bureau to provide Canadian credit information.

To rely on a credit file search, you must conduct the search at the time you ascertain your client's identity.  In other words, you are required to consult the credit file as part of the process to verify your client's identity.  To be acceptable as a single source:

The credit file must match the name, address and date of birth that the client provided.

The credit file must be from Canada; foreign credit files are not acceptable.

The credit file must have been in existence for at least three years.

What information needs to be recorded when using the credit file method?

If you are using this method to ascertain client identity, you must record: 

The client's name

The name of the Canadian credit bureau holding the credit file

The reference number of the credit file

The date you consulted or searched the credit file

Dual process method

You can ascertain the identity of a client using the dual process method.  This method involves referring to information from reliable and independent sources. The information may be found in documents from these sources or may be information that these sources are able to provide. If you refer to a document, you must view the original, valid and current document. If you refer to information provided from a source, it must be valid and current. The client does not need to be physically present at the time you ascertain their identity.

What is a reliable source?

A reliable source is an originator or issuer of information that you trust to verify the identity of the client.  When you are relying on a source to verify a client's name and address or a client's name and date of birth, the source must be reliable. The source should be well known and considered reputable. The source providing the information cannot be you, as the reporting entity, or the client; it must be independent.  For example, reliable sources can be the federal, provincial, territorial and municipal levels of government, crown corporations, financial entities or utility providers. 

What is an acceptable original document?

If you are referring to a document in the dual process method, you must ensure that you see the original paper or electronic document and not a copy.  The original document is the one your client received or obtained from the issuer through posted mail or electronically. The document must appear to be valid and unaltered in order to be acceptable.  If any information has been redacted, it is not acceptable. 

For example, an original paper document can be a utility statement mailed to your client by the utility provider. Whereas an original electronic document is one the client received through email or by downloading it directly from the issuer's website.

Your client can email you the original electronic documents they received or downloaded, or your client can show you the document on their electronic device (for example, a smartphone, tablet, or laptop).  Your client can print electronic documents that they receive or download from the issuer, or they can show them to you in their original format such as .pdf (Adobe) or .xps (Microsoft viewer).  Original documents do not include those that have been photocopied, faxed or digitally scanned. 

Examples

The client can show you their original paper utility statement in person or by posted mail.

The client can email or show you on their electronic device an electronic utility statement downloaded directly from the issuer's website.

The client can print and show you the statement they downloaded from the issuer.

The client can email or show you on their electronic device a mortgage statement received by email from the issuer.

How do I use the dual process method to ascertain the identity of my client?

To use the dual process method to ascertain a client's identity, you can refer to any two of the following categories:

Documents or information from a reliable source that contain the client's name and date of birth;

Documents or information from a reliable source that contain the client's name and address; or

Documents or information that contain the client's name and confirms that they have a deposit, credit card or other loan account with a financial entity.

You must refer to original documents or information from two independent, reliable sources to ascertain your client's identity, and all the information must match the information provided by your client.  If you refer to an original document that has an expiry date, it must be current, and if there is no expiration date, it must be a recent version of the document.  For example, if your client provides you with a credit card statement or a Canada Revenue Agency (CRA) notice of assessment, it would need to be the latest one received by your client. 

You cannot rely on information issued by a single source, even if it confirms an account and contains the name, address and date of birth.  It is also important to note that you cannot use the same source for the two categories of information you use to ascertain the client's identity. For example, you can refer to a bank statement that contains the client's name and address from Bank A and confirm a deposit account at Bank B. It would not be acceptable, however to view a statement from Bank A, and confirm a deposit account at Bank A. As another example, you cannot rely on a CRA document that contains the client's name and address and a different CRA document that contains the client's name and date of birth, because the CRA is the same source for both documents.

Table 2 provides examples of information you can rely on to ascertain client identity using the dual process method.  You must use original documents or information from two independent and reliable sources to ascertain your client's identity. For example:

You use one source to verify your client's name and address and a second source to verify their name and date of birth. 

You use one source to verify your client's name and address and a second source to verify their name and confirm a financial account. 

You use one source to verify your client's name and date of birth and a second source to verify their name and confirm a financial account. 

XAGATE uses the dual process method of verifying the identity of user's for record keeping obligations.  Due to these updated guidelines, it is in the best interest of Canadian Money Services Businesses to consider partnering with Equifax, TransUnion, or Trulioo to verify their client's identity (the latter of which I am personally investigating at this time in comparison to the former).  Please note that if you conducted a policy in which you receive any sort of identity that is not provided in person, it is not valid nor reliable, hence a credit file verification method is ideal for Ripple Gateways.