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A mortgage applicant provides a valid Social Security card and driver's license, but the SSN was issued in a state different from where the applicant claims to have lived their entire life. Under CIP requirements, this situation:

Correct Answer

B) Requires additional verification but may be resolved with reasonable explanation

Under CIP requirements in 31 CFR 1020.220, discrepancies in documentation require additional verification, but there may be reasonable explanations (such as being born in a different state). The lender should seek clarification and additional documentation rather than automatically rejecting the application.

Answer Options
A
Automatically disqualifies the applicant from obtaining a mortgage
B
Requires additional verification but may be resolved with reasonable explanation
C
Mandates immediate SAR filing for identity theft
D
Violates CIP requirements and must be reported to FinCEN

Why This Is the Correct Answer

Under CIP requirements in 31 CFR 1020.220, discrepancies in documentation require additional verification, but there may be reasonable explanations (such as being born in a different state). The lender should seek clarification and additional documentation rather than automatically rejecting the application.

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