How to Prove Every Customer’s Identity

How to Prove Every Customer’s Identity
Occasionally, even the seemingly simplest tasks become fraught with minutiae that encourage some to make it more difficult or cumbersome than necessary. The latest example of this idiom surfaced in a dealer’s quest to sell and finance a vehicle to an individual who could not provide a government-issued photo identity to prove she was who she said she was.
This customer presented a driver’s license without a photo. Instead of a photo, there was a state seal and the words “Valid without photo.” Her explanation was that she was a Department of Defense employee and this was a valid ID.
The dealer’s Red Flags policy is very straightforward: Each customer must provide a valid, current, government-issued photo ID. Similar requirements to confirm a customer’s identity are resident in finance source agreements, the USA PATRIOT Act and good risk-management practices.
Her ID and the dealer’s identity-confirmation policies are at odds. How is the dealer supposed to sell a vehicle in instances such as this? How about another recurring scenario in which a customer presents a driver’s license with the phrase “Not valid for federal identification.”
Thankfully, there are options.
Behind the ID
There is not a nationwide ID card issued by the United States, and the state driver’s license is the de facto ID. A few reasons complicate the ability to confirm a customer’s identity:
Customer does not drive
Customer is active-duty military in a state that does not require a current state driver’s license
Customer has recently applied for a driver’s license and has a temporary ID without a photo
In these cases, an alternative form of photo ID must be obtained as identity confirmation. A few federal laws also play into the scenario of alternative IDs. One law prohibits anyone from making a photocopy of a military ID except to be used for the customer’s benefit. Applying for a military rebate does not quality as a reason to make a photocopy of the ID.
The REAL ID Act also applies. Passed in 2005 but not fully enforced until 2020, this law requires anyone who wants to board a plane or enter a federal facility to provide an ID which conforms to the standards provided under the act. Forty-five of the 50 states have a vetting process to issue driver’s licenses and state IDs that meet these standards, and if a consumer is unable to provide the full documentation necessary, she or he receives an ID with the phrase “Not valid for federal identification.”
An Agent’s Responsibility
As an agent, if you have any interest in keeping your clients on the right side of these laws, you must encourage them to apply the same standards to confirming an identity as the standards found in other identity-vetting programs. Banks are required to confirm the identity of anyone opening an account. The TSA is responsible to identity anyone flying on a plane. State DMVs must ensure anyone receiving a driver’s license or state ID is who he says he is.
In those small percentage of times when the customer is unable to provide a valid, current, legible photo driver’s license or state ID card, your dealers must obtain an alternative form of photo ID. Some examples include:
Military ID (with the aforementioned caveat against making unauthorized photocopies)
Department of Defense Common Access Card (to which the photocopying standard also pertains)
Passport issued by the United States or foreign nations
U.S. passport card
Global Entry or NEXUS ID card
Gun or concealed weapon license that includes a photo (in states that issue them)
Ultimately, a dealer’s responsibility is to confirm the person purchasing a vehicle is not an identity thief, and this starts with vetting the identity provided. When using a military ID as an alternative form of ID, have the salesperson complete the following statement and sign it:
“I certify I reviewed a military ID or a CAC for [name of customer]. I confirmed the photograph is the same as the person providing the ID. I confirmed the height and eye color are consistent with the person providing the ID. The ID was issued on [date] and expires on [date].”
They should also confirm that the information on the credit application matches the story provided by the customer and use an internet search engine to confirm what the alternative form of ID should look like. Finally, they must verify the driver’s license number or state ID number with the state DMV and retain documentation.
Good luck and good selling.
More Industry

Autos More Appealing
Consumers gave new cars better scores again this year for design, performance and more as mass-market brands kept gaining on premium lineups, JD Power found in an annual poll.
Read More →
Used EVs Defy Overall Market
While the used-car market saw three months of price declines or stagnation, the used EV segment did the opposite – rising for three straight months.
Read More →
Gone to the Dogs
A Stellantis brand decided to have some fun with one of its SUVs’ design to address growing emphasis on family pets.
Read More →
OEM Poll Sees Industry Evolution
Kerrigan Advisors’ survey of automakers finds that tariffs, technology, network tightening and other factors are poised to reshape auto retail.
Read More →
Luxe N.C. Dealerships Change Hands
A collection of Italian and English brand franchises were handed off to the owner’s friend in the business and include the Carolinas’ only Ferrari retail stores.
Read More →
Exposure Drives Interest in Chinese Cars
At a recent demonstration, consumers had the chance to ride in a Chinese-branded vehicle, a firsthand experience that improved their perceptions and purchase intent.
Read More →
Automotive Consumers Sink Further in Debt
Most financing metrics hit records in the second quarter as more buyers locked themselves into long terms and high monthly payments.
Read More →
Agent Advocate
Rob Mancuso, who comes from a long line of auto dealers, values general agents’ place in the industry and makes a case for them taking an even bigger seat at the table.
Read More →
Driving Under Distraction
Though consumers gave higher marks to new vehicles in JD Power’s most recent initial-quality poll, high-tech interference worsened, pointing to craving for simplicity.
Read More →
Affordable New Cars a Thing of the Past
More than one out of five new vehicles sell for more than $60,000, according to Edmunds. That's up 7% compared to prepandemic 2019.
Read More →