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Verifying the identity of an individual client – credit file method

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In brief: You can use the credit file method of verifying an individual’s identity in situations where the individual has a credit file located in Canada that has been in existence for at least three years. This is not a credit assessment to obtain a credit rating for the ability to pay a loan. Current information in the credit file is used to verify that the name, address and date of birth in the credit file are those of the individual. The information in the credit file must match the name, address and date of birth that the individual told you. Before using this method, obtain the individual’s consent. This method does not require the individual’s presence for verification. Equifax and TransUnion Canada are Canadian credit bureaus that provide credit file information for verification of ID purposes. You can apply to access their services to verify ID without getting a credit assessment.  There is a detailed application process that may take a week or more to complete.

Key Resources

Rules - Verification using an individual’s credit file: Law Society Rule 3-102(1) and (2)(ii).

Rules - Law Society Rule 3-109.

Code - Dishonesty, fraud by client: BC Code rule 3.2-7.

Practice Resource - Red Flags Quick Reference Guide

Practice Resource - Learn more about client verification requirements and methods:  Client ID & Verification - FAQs.

Practice Resource - Client Identification, Verification and Source of Money Checklist, updated to September 1, 2023; includes Sample Agreement with Agent for Verification. (Note the changes to Law Society Rules 3-102 and 3-104 made on March 8, 2024 that affect parts of this checklist.) 

Additional Reading

Practice Resource - Anti-Money Laundering Webinar: See in particular 1:10:00.

Rules - Definitions of “financial transaction” and “money”: Law Society Rule 3-98.

Rules - Exemptions to verification requirements: Law Society Rules 3-99 and 3-101.

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