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Maintaining Customer Identification Programs During COVID-19

Since 2002, lenders have been aware of the importance of Know Your Customer (KYC) and the associated Customer Identification Program (CIP) requirements. As COVID-19 has changed procedures and priorities for businesses and consumers across the board, it’s more important than ever for institutions to ensure their CIP process includes ongoing monitoring of identity risk.

What is CIP?

Standard KYC programs include a Customer Identification Program to verify and validate identities along with due diligence to assess the risks associated with each identity.

CIP defines the process by which a business collects data to establish a reasonable belief that the identity is valid, and that the individual is eligible to participate in our financial system. While this process works in conjunction with other fraud mitigation tactics, they serve different purposes. A good CIP program emphasizes the customer experience, regulatory compliance, cost control, and smart growth. Fraud mitigation focuses on ensuring that an eligible identity is being presented by its true owner, rather than as part of a scheme to acquire goods and services with intent to default on repayment obligations.

Businesses who focus on solely on fraud mitigation rather than complying with KYC and CIP regulations run the risk of potential harm to business reputation, and of course, financial penalties. Fenergo found that as of the end of 2019, global penalties for AML and KYC non-compliance totaled $36 billion.

CIP vs. Fraud Mitigation

Many financial institutions equate a CIP program with efforts to mitigate fraud. It’s understandable, as both processes include emphasis on the accuracy of an identity as it’s presented by a consumer. It is assumed that only the true owner of the identity would possess the detailed information necessary to meet CIP requirements and therefore would not likely be committing fraud.

There was a time—prior to large scale thefts of stored information, personal details shared through social media and other behavior changes that made personal information very public—when this would have been true. Unfortunately, those days have passed and even an amateur criminal with limited experience and resources could find current, accurate identity information for sale online, information good enough to pass the CIP test and be considered a legitimate consumer.

The real challenge is that when they go through CIP, many real consumers may inadvertently provide true information that doesn’t meet the verification standard. This is a result of consumer lifestyle changes outpacing the sources of data used to verify the information they’ve provided. It makes sense; in most years roughly 13% of American adults change their address. New homes, job changes and changes in marital status impact a large number of people every day. Adding to the confusion—it’s life’s changes that prompt people to borrow and purchase. The result is that many of the people that are more likely to fail CIP verification are the very people trying to legitimately access financial services.

The result is that CIP verification often isn’t a challenge for those intending to commit fraud, but it can be for genuine consumers.

The challenges of CIP

In a recent internal study, Experian reviewed the ability to pass a standard CIP strategy that assessed the accuracy of the name, current address, date of birth and Social Security number provided by a large sample of consumers. We then compared legitimate consumers to those later confirmed to have been identity thieves impersonating a victim. Consistently, the identity thieves were at least as proficient at passing CIP as their true-consumer counterparts.

In a second step, we applied a fraud score that looked for identity theft by assessing the past uses of the identities, their consistency, velocity and many other characteristics unrelated to the accuracy of the data. The difference between CIP verification and a fraud risk assessment was striking. Across the entire range of fraud risk, the percentage of records that passed CIP verification remained the same.

That said, CIP still plays a very important role in risk mitigation. In fact, CIP and fraud prevention are inextricable in financial services. Just as a CIP verified identity can still be fraud, a record that may appear to be low fraud risk may not pass CIP. Since both processes have existed side by side for nearly two decades, each presumes that the other is in place and both are necessary to detect and prevent fraud.

Striking a balance

CIP verification and fraud mitigation strategies are both necessary and important to protecting assets and the broader financial system from fraud. It’s important to leverage a layered approach where both eligibility and risk are assessed, and next steps for verification include resolution of identity discrepancies alongside verification that ensures an identity is not being misused for fraud.

Experian can help you confidently verify customer identities, understand and anticipate customer activities, and implement ongoing monitoring. If you’d like to set up a review of your current strategy or learn more about how we can help you with CIP and fraud mitigation to strengthen your ability to know your customer compliantly, let us know.

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