In response to the rapid escalation of the COVID-19 pandemic, we have received several policy updates from our lender partners about your requirements when conducting non-face to face meetings and verifying your client's identification.
We will continue to work with lenders to keep this page updated to help you meet your requirements, so stay tuned.
VoI- Changes to our verification procedures
On Monday, 27 April 2020, We released access to NextGen.net’s Documentation Verification Service (DVS) to assist in the identification of our mutual clients during their loan applications.
In addition to AMP’s current VOI procedures, we have introduced an additional measure to allow brokers to now verify their clients' ID through video conferencing technology such as ZOOM, Skype, FaceTime and WhatsApp.
With the update to VOI procedures section, 13 of the Home Loan Application Form has been updated and must be ticked in order for the online VOI to be completed. This is currently a temporary measure and will be reviewed in September.
We remind you of the importance of your client providing their specific consent and therefore completing the revised section 13 on the Loan application form. Refer to the image below:
You may not be able to source this in the online application form with Applyonline. If this occurs please access the manual application form available in Distributor Centre at www.amp.com.au/distributor/forms and ensure that this is used to complete the application. We are working quickly to resolve this.
For more information refer to our previous newsletter, read our FAQs, read our guide or speak to your Business Development Manager
ELECTRONIC AND DIGITAL SIGNATURES
For a deal to be eligible for e-sign it has to be an individual borrower structure, submitted through App Centre/AOL and loaded by AMP's Operations team using App Centre. The applicants must be opted into E-communications and we must be provided with a valid and unique:
- Email address for each applicant
- Mobile number for each applicant
There are also restrictions based on states laws/regulations surrounding e-sign, that may override.
ANZ eVerify - DIGITAL CONVENIENCE FOR YOUR CUSTOMERS
Effective 25th May 2020, we are introducing ANZ eVerify.
ANZ has introduced a new customer-focused digital ID process, ANZ eVerify.
ANZ eVerify is focused on a digital ID process for our home loan customers satisfying Know Your Customer (KYC) and Verification of Identity (VOI) requirements electronically. This will significantly reduce the need for most customers to attend an ANZ branch.
ANZ eVerify is targeting new and existing Home Loan customers to ensure we meet our VOI obligations which require us to confirm a customer’s identity every 2 years.
If your customer is unable to or would prefer not to verify their identity electronically they can still visit an ANZ branch.
Note: All Complex/Non-Individual KYC requirements must continue to be completed in an ANZ branch.
As this is all new, there is a dedicated support team to assist you and your customers' with the new ANZ eVerify process.
The support team can be contacted via email on email@example.com for the following general enquiries:
- "How to" queries
- Resending links to customers
- Cancelling requests
- Checking on the status of the ANZ eVerify request
For urgent escalations email firstname.lastname@example.org (i.e. if settlement is due and the customer has not yet completed ANZ eVerify).
What you need to do
- From 25th May 2020, don't forget to let your customers (new to ANZ or existing) know when their application has been fully approved they will receive an SMS containing a link asking them to verify their identity.
- To ensure this SMS is effective, please ensure we have an up to date mobile number and email address for each customer in the application.
- To support you and our customers, please visit anz.com/support/anz-eVerify to view a short 'how-to' video.
We are able to offer temporary alternatives to our usual face-to-face home loan processes.
These changes are to assist customers and/or brokers who are self-isolating due to COVID-19, however, where both broker and customer are comfortable to meet face to face, brokers should continue to do so where appropriate and follow existing processes.
These temporary processes will be in place until otherwise advised:
Digital Interviews and Verification of Identity
Effective immediately, an interview in relation to a home loan application can be completed using digital technology i.e. Skype, MyMeeting, Facetime, without seeking your BDM approval:
- Guarantor interviews may now also be completed through video call (not phone) where a face-to-face interview is not possible, with additional questions to ensure guarantors are not under duress.
- For existing ANZ customers (where KYC has been completed within the last two years) the interview may also be completed by phone. For more information and to access the process document, please refer to the Broker portal.
Note: Brokers must remember to record whether the interview was conducted remotely or face-to-face in the Broker Interview Guide.
Opening transaction accounts (including Offset)
Effective immediately, an alternative option for sending customers to a branch for opening a deposit/transaction account in a single name is available.
- For sole account holders: Our Customer Contact Centre is able to assist customers on 1800 317 364 (available Monday-Friday 8 am-8 pm AEST)
- For joint account/multiple account holders: We are currently working through a process to assist these customers. We will provide further communications to address this as soon as possible.
ELECTRONIC AND DIGITAL SIGNATURES
Effective immediately, the following option is available for the signing of home loan application documents:
- Application Form/ Statement of Financial Position: Where the customers and/or brokers have access to the use of digital signatures they will now be acceptable (e.g. Docusign).
- Physical signatures are still required as per the current process for Letter of Offer/Mortgage Document & Witness Acknowledgement and all Guarantor documents.
- All documents requiring a signature by a Guarantor must be physical signatures as per the current process.
NON-FACE TO FACE INTERVIEWS
Our position regarding the acceptance of applications where a customer has not been interviewed face to face has not changed. Non-face to face interviews are acceptable to Auswide Bank provided this style of interview is approved by your Aggregator and that all steps to meet their compliance requirements are adhered to.
METHODS OF CONDUCTING VERIFICATION OF IDENTITY
If you are meeting the customer face to face physically, you can use ZipID App and complete the Verification of Identity to meet both our AML/CTF and VOI requirements. (ZipID App can be downloaded via the Apple App Store or Google Play with no cost incurred by you or the customer.
If you are unable to meet the customer face to face physically to verify their identity, they can take one of our VOI firms to an Australia Post office, along with the correct required id documents and will be identified there. There is NO cost to the customers to complete their VOI with Australia Post.
Our VOI forms can be located on our broker website. Please refer to full details of all VOI requirements located on our broker website here.
We are continuing to investigate other options for electronic VOI and will continue to update you with changes in this space as this progresses.
ELECTRONIC AND DIGITAL SIGNATURES
There is no change to our policy at this stage relating to the use of client and broker electronic or digital signatures in our Broker Pack. In particular the broker declaration, client privacy declaration forms and new account forms.
Electronic signatures being merely an image of a signature overlaid on top of a PDF document, (i.e. use of a ‘scanned’ signature image pasted onto a document, or using a feature of a software app such as Adobe to ‘create; a signature).
Although digital signatures are cryptographically secure and use private signing ‘keys’ to verify who has signed the documents and authorised it (e.g. DocuSign; DigiDocs) at this stage this option is not available.
The use of Digital signatures on our loan documents is currently being investigated at this time. We will continue to update you on any changes to our current policy in this regard as they develop.
As we make further additions to our acceptable electronic VOI arraignments we will keep you updated.
* Changes to our credit policy-with the impacts of COVI-19 starting to affect employment sectors and types of employment, we have updated our credit policy with regards to Casual Employment and applications requiring LMI.
Please refer to our Broker website for full details.
New to bank customers- AML/CTF (KYC)
All customers- Identity Verification and Privacy Consent (IVPC)
Customers unable to access hard copies
With concerns growing about the safety of face-to-face identity verification, we have now enabled remote VOI via IDyou.
In case you’re unfamiliar; IDyou by MSA allows mortgage brokers to perform a secure VOI remotely, from anywhere.
- It’s an app that has inbuilt video call functionality to support the remote verification of identity.
- It allows you to verify your client face-to-face via video call.
- The IDyou report is sent to the lender and used as evidence that a video call took place.
Take a look at this short video illustrating exactly how the process works.
If you’re having trouble:
- Check out the remote user guide for brokers and customers.
- Read the FAQs.
- Visit their website for more information.
Bank of Queensland
Temporary COVID-19 identification exceptions
When you are interviewing a customer remotely and that customer is unable to visit an approved certifier, due to being in self-isolation or other reason related to COVID-19, BOQ will waive the requirement for certification of identification documents where the following process is adhered to:
Confirm with the customer that they are unable to provide their identity documents face-to-face due to COVID-19 limitations.
- Advise the customer that we can accept uncertified copies of their identification, along with a copy of their utility bill showing their name and address (e.g. gas, telco, electricity).
- Accredited Broker must complete the Certified ID form and record “Not Certified” under the section ‘details of certifier’. The Certified ID form can be generated from ApplyOnline or downloaded from our portal.
- The broker must still compare photocopies of the documents received by email with those displayed on the screen by the customer during the video-conference interview and take a screenshot of the customer holding the ID, as per the Remote Interview Guide.
- The broker must then complete the broker declaration section of the Certified ID form.
- Upload the identification documents along with the utility bill, the video-conference screenshot and the Certified ID form to ApplyOnline, along with the other supporting documentation. Please note: BOQ will not accept these documents via email. Documentation must be uploaded to ApplyOnline supporting documents when the application is submitted.
This is a temporary process only to assist you in navigating the challenges presented by the current environment.
For further information or if you have any questions, please contact your BDM.
Same policy and guidelines still apply to all brokers. No change to policy
Policy as per below:
- Whilst a face to face interview is preferable, our agreement caters for non-face to face situations
- All the Bank requirements must be followed, noting our AML / KYC requirements where the broker cannot verify from original identification documents.
- In such cases, the Certified Copies (Prescribed Persons) method is to be used.
- Refer to Comm Broker for instructions including the use of the Certified Copies of Identification Form.
- Please note that identification responsibilities cannot be outsourced to any third-party provider.
- Licensees policies/procedures/controls need to include the following:
- Customer Privacy Consents to cater for video conferencing
- Applicants face must be clearly visible, and the applicant must be audible during the interview and each applicant must be visible when communicating
- Appropriate scripting (including questions) to:
- Determine whether there are any other parties, who are not associated with the loan, present and if they are whether the applicant consents to their presence. Brokers should at this point look for any duress or undue influence on the borrower and decline to proceed if any concern
- Confirm that customers are willingly participating in the video conference
Further, all brokers need to be aware of the requirements from the Federal Government around self-isolation and if the customer does happen to be ill.
ELECTRONIC AND DIGITAL SIGNATURES
Currently CBA do not accept e-signatures and digital signatures for any of the Home Loan Onboarding Forms, contracts or other documents. They are only accepting e-signatures and digital signatures on Contracts of Sale and Building Contracts at this point in time.
Effective immediately Citi has updated its Verification of Identity policy (VOI) to allow a broker who cannot meet with a client(s) in person to utilize virtual /digital platforms to interview the client and complete VOI until further notice.
The process below is to be followed in this instance:-
- The broker is to complete the application in ApplyOnline as per normal business practice.
- When conducting the VOI: the client(s) must show the broker the required original identification documentation via the digital platform and this must be clearly sighted on screen.
- The broker must record details of the original identification documents sighted on the Customer ID/ AML and Responsible Lending forms. The broker is required to use the revised “Citibank Home Loan Introducer Acknowledgement and Checklist” when completing the VOI digitally ensuring this form and a copy of the identification documentation is provided with the supporting documents for each application.
If there are any doubts raised about the identity of the client(s) either via the broker or as a result of Citi’s internal processes, further investigations will be required.
Connective Home Loans
All Connective Home Loans funders allow remote client meetings. All Connective Home Loan funders allow for verification of Identification to be completed at Australia Post, via ZIP ID, or a combination of both.
Face to face and remote identification methods
- We will now resume accepting customer identification verification face-to-face via IDyou, ZipID or the Australia Post form
As states ease restrictions for public gatherings it’s likely that aggregators will ease strict social distancing measures, so we will resume accepting customer identity verification for Know Your Customer (KYC) and Verification of Identity (VOI) requirements via:
- IDyou app (either In-Person or via Remote Verification)
- ZipID (In-Person only)
- Australia Post ID form (customer completes in Australia Post Branch)
Any other way to check a customer’s identification won’t be accepted including using our 100-point ID form.
Where States allow face-to-face meetings, and as a result your aggregator allows face-to-face meetings, provided it is safe to do so, you can continue to perform interviews face-to face-with your customers.
We also allow video conferencing interviews to conduct the loan application interview.
Video Conference Interviews and Remote ID verification
If you are not meeting a customer face to face and interviewing your customer via video conference and utilising IDYou Remote, you will need to:
- sight your customer with their original identity documentation
- review these ID documents presented in the video call and compare it with the ID information the customer submitted via the IDyou app
- Document within your submission notes, the customer identity documents presented during the video interview and method of the video conference. Here’s a sample of what you can write:
“I held a (describe the video method used. e.g. Zoom, facetime etc.) interview on (insert date) and during this interview, the customer displayed their (insert ID sighted).”
Advantedge requires a minimum of one photographic ID document, but preferably two.
Remain vigilant to loan application fraud
You’re reminded to remain vigilant during this pandemic period and be aware of the heightened potential for loan application fraud.
If you suspect any potentially fraudulent or suspicious activity, please raise this with your BDM immediately.
For further information on using the IDyou or ZipID apps and video interviews, visit http://theadvantedgeedge.com.au/
Document Verification Service update
- From Monday 25 May 2020 there will be some updates to the Document Verification Service (DVS) feature in ApplyOnline to strengthen upfront validation of identification (ID) documents.
We recently introduced DVS in ApplyOnline help improve application turnaround times by validating ID document information upfront and ensuring that the identification information entered is correct.
These are the latest updates:
- Removal of the 100 Point ID Check form
Regardless of the DVS outcome, the 100 Point ID Check form will no longer be required and will be removed from both short and long application forms. This includes where an ID document used is not in scope for DVS. Note: IDyou, ZipID or Australia Post form must be used to ID a customer.
- New Verification method selection in Applicants tab
In the Applicants tab, you will see a dropdown menu where you will need to select from the options: Australia Post, IDYou, and ZipID.
- You will be required to provide a minimum 100 points worth of ID documents
Ensure that the information you enter into DVS is from the documents you’ve captured in the IDyou or ZipID apps.
- ID documents must be current
The ID documents you use for the loan application must not be expired at the date of the application. This includes:
- Australian Government Pension/ Social Security/Health Care Card
- Australian Student Photo ID Card
- Identification card/permit
- International License or ID Card
- Australian Medicare Card
If you submit an expired document, you’ll see an on-screen error message stating that the document chosen cannot be used as it has expired.
The only exception to this is for an Australian Passport, which must be no older than two years after its expiry, at the date of application.
- New mandatory DVS declaration for app submission
You will see a new mandatory declaration in the Compliance tab before being able to submit an application. If you choose Australia Post as a verification method, this declaration does not apply. In the absence of a declaration, you may be contacted to provide a declaration by email.
- New DVS Declaration if DVS document fails
If any one of the documents fail DVS (this may happen for a number of reasons), an additional broker declaration will appear under the Compliance tab. You must agree to this declaration before being able to submit the application.
If you have further questions, please contact your BDM.
CHL Solutions will continue our business process of allowing non-face to face customer interactions with VOI identification via Zip ID or Australia Post. We are also working on digital verifications should the current VOI options become unavailable and will enact this immediately in need.
* Changes to credit policy- effective Monday 30 March 2020, there are changes to the documentation requirements to verify PAYG and self-employed income. Please refer to the Broker portal for more information.
Face-to-face Broker Meetings
Firstmac does not require the broker to conduct a face-to-face interview with a client prior to lodging an application or to view client identification documents. However, our mortgage document pack which includes a VOI form requires original signatures. The VOI form must be completed by a prescribed person listed on the form and the mortgage documents will still need to be witnessed. This process is currently being reviewed with the Titles Offices in each state and we will provide you with an update
If you are unable to complete a face-to-face verification, please follow these steps:
- Obtain copies of ID for each party to the loan and confirm reasonable likeness.
- Call each party to explain how InfoTrack works and obtain consent to proceed. You can provide the 'Completing a WebVOI - Verification of Identity' flyer to the applicant, available on the Heritage Brokers site, under Forms & Brochures.
- Complete the VOI certificate, make sure the 'By InfoTrack' box is ticked under the 'Identification Documents' section.
- Upload completed VOI certificate to NextGen ApplyOnline.
- Once conditionally approved by Heritage, the applicant will receive an email from InfoTrack to complete the process. Please ensure you have the applicant's email and mobile number correct.
Please advise your clients that a Heritage team member will send them an email and phone them to finalise completion of the VOI.
Procedures have not changed where you are still able to complete a face-to-face verification. VOI is to be completed at time of interview and certified identification documents are to be forwarded with the loan application via NextGen ApplyOnline.
If you have any questions about the digital VOI process, please contact your Heritage BDM.
Further to the previous advice of 18 March 2020, ING is pleased to advise that effective immediately, where a face-to-face interview between broker and client is not possible, ING will allow brokers to conduct customer identification using video-based technology. This digital method of identification will add to the more traditional methods still available as outlined in the broker update of 18 March 2020.
Below are the steps to follow when using video technology, allowing a seamless ID verification process:
- Broker to request and receive copies of an applicant’s identification documents (list of acceptable documents outlined in the ING Identification form)
- The broker arranges for a video meeting with applicant(s) to be identified
- Applicant displays the original identification documents on the screen camera. The broker then validates:
- The documents in the video are the same documents as the copies provided to the broker
- The likeness of the applicant is identical
- The documents appear valid and accurate
Verification of Identity
Following verification of the applicant’s ID, the broker then:
Completes the application in ApplyOnline as per the standard process
- Completes the new ING Identification form (attached) indicating the method of ID verification used in the declaration. This has been made available on our introducer site and will be updated on ApplyOnline in due course.
- Submits the ING Identification form and supporting documents as per the standard process
Please note: ING reserves the right to request face-to-face verification of ID where there is any uncertainty as to an applicant’s identification.
ING will also allow clients to be identified via Zip ID. ING has an arrangement in place for Zip ID to carry out mobile face-to-face identity verification as ING’s agent. More information about Zip ID can be found at zipid.com.au
Zip ID may be used in the same circumstances in which Australia Post identification is permitted under the ING Customer Identification Procedure for Brokers (see para 220.127.116.11). In order to utilise this option, brokers will need to register for Zip ID credentials via ING.
Those credentials will give the broker access to the Zip ID portal that allows them to arrange the appointment between Zip ID and the client for the purposes of face-to-face identity verification. Registration instructions will be provided in an email to accredited brokers shortly. The addition of this option is effective immediately and now available to accredited brokers.
ELECTRONIC AND DIGITAL SIGNATURES
Effective immediately, applications submitted via AppyOnline can be accepted with electronic signatures using an electronic signature platform (e.g. DocuSign). This will apply to lending for new home loan customers and existing ING home loan customers.
The forms to which the above will apply to include:
- Loan application form
- Residential Loan Variation request form
- Identification form
- Fixed Rate Lock In Request form
- Delivery of Loan Documents form
The addition of electronic signatures has been introduced to further simplify the application experience, complementing recent announcements which allow brokers to verify the identity of home loan applicants via digital video technology.
Should you have any queries regarding the above or for any other matters, contact your ING representative or call the Sales Support Unit on 1300 656 226, Monday to Friday 8:30 am - 6:00 pm (AEST).
Verification of Identity (VOI) guidelines
Landgate has acknowledged that with the current Covid-19 pandemic it may be difficult to conduct full face-to-face verification of identity.
If you are therefore unable to complete a face-to-face identification with your customer(s) Keystart will now accept the following:
1. Obtain written confirmation from the customer/s (email/screen of text) why they feel a face to face with either the Broker/Introducer or Australia Post is not appropriate. e.g. Due to restrictions from COVID-19 and/or self-isolation.
2. Complete the current VOI form and ensure in the “where” they advise:
- Where each party was located (Introducer “Subiaco” and client “Cannington”)
- The method they used to do a live video conference to verify the ID they have in their possession i.e. zoom, FaceTime, Skype etc.
- Complete the rest of the form in line with landgate requirements.
Should the customer accept the alternative solutions of zoom, face-time, skype etc. then it is important that you follow these steps to ensure you are satisfied that you have made reasonable steps to identify your customer.
1. Have a copy of the Photo ID in front of them when they do the live video conference.
2. The client places their original documents against their face on the video to allow confirmation that the person being identified has similar facial characteristics.
3. That the identification cannot proceed via video if the resolution of the video is of poor quality to enable the identification.
Alternatively, customers can still visit an Australia Post office to have their identity verified should they choose this option.
Verification of customer email address and mobile phone details
As previously advised, Keystart now require unique mandatory mobile phone and email (MME) details for each applicant in order to facilitate electronic communications and provide the customer with access to Keystart’s Application Tracker.
Once you have submitted an application via the Keystart Broker Portal, an automated email will be sent to the customer. This email will request the customer(s) to verify their email address and mobile number via a two factor authentication process.
If your customer advises they have not received the verification email, please check the new Application Tracker tab in the Broker Portal and ensure their email and mobile details are unique and correctly loaded. You can then resend an invite if required.
Reminder emails will be sent to both yourself and your customers every 24 hours if customers have not verified their details and registered for Keystart’s Application Tracker. Please ensure you follow up these email reminders with your customer otherwise the application will be blocked and not be placed in the assessment queue.
When are the changes effective from?
The above changes have been in the portal for quite some time, however, the application turnaround start date will now only start once your customers have verified their details so it is important that they do this as soon as possible. This change has become effective today.
What do you need to do?
Please ensure your customers are aware of these new MME details so that they verify their details as soon as possible following receipt of the automated email from Keystart.
If you have any questions with regards to any of these changes, please contact Leigh Karangaroa, Broker Relationship Manager on 0419 904 573 or email@example.com or our Broker Support Team on 1300 366 055.
We thank you for your ongoing support and look forward to our continuing role in assisting more Western Australian’s into affordable home ownership.
We’re introducing an update to our Verification of Identity (VOI) process to help you with client identification during the coronavirus (COVID-19) situation.
If you’re unable to meet with a client in person, you will now be able to conduct the VOI process via video technology (such as Skype, FaceTime, or Zoom).
Please note this is a temporary measure during the COVID-19 period and we’ll advise you of any further changes to this process.
What you need to do
We’ve outlined the steps to follow to verify your client’s identity via video call.
- Ask your client for a scanned copy of their identification documents before you begin the video call.
- On the video call, your client will need to hold up their original identification documents so you can compare the photo in the identification documents to their face in the video and confirm they match.
- Confirm the scanned documents you’ve received match those presented by your client and also confirm the reasonable likeness of the person on the call to the person in the photo on the identification documents.
- In the ‘Date and location of interview’ section of the ‘Home Loans ID Form’, you’ll need to note that the interview was completed by video call and details of the call including the date and the program used for the call. For example Interview via video call, 6 May 2020, Skype.
- If you’re not satisfied that the video call or documents shown meet your verification of identity requirements, your client can also have their identity verified using the ZipID ‘come to you’ service or with an in-person interview at their local Australia Post branch
COVID-19 was declared a pandemic by the World Health Organisation on 11 March 2020. In response, ME has established a business management plan to protect our people, brokers and customers, and to ensure the smooth running of our business.
ME’s amended requirements- acceptance of the use of digital meeting platforms
Over the last few days, we have experienced an increase in enquiries from both brokers and aggregators regarding whether ME accepts brokers conducting remote and/or digital meetings (i.e. Skype), as well as clarification of our Verification of Identity (VOI) policy.
With the expected increase in customer preferences to conduct home loan interviews digitally over the coming weeks, ME would like to help support brokers to continue to service their customers so we have changed our policy to permit both the customer interview and VOI of the customer to be completed via digital means.
Meeting the customer(s) face-to-face:
Where a broker meets with the customer(s) in person and can complete the VOI of the customer(s) in person, the “Customer ID, Responsible Lending and Broker Declarations (Face-to-Face)” form should be used in every instance. This will form part of the ApplyOnline document pack generated on submission of the loan to ME and can also be found on our broker website.
Meeting the customer(s) via digital platforms (e.g. Skype, FaceTime):
Where a broker cannot meet with the customer(s) in person, digital platforms may be used for the purpose of interviewing the customer and completing the VOI. The process below is to be followed in this instance:
- The broker is to complete the application in ApplyOnline as per usual business practice.
- When conducting the VOI: the customer(s) must show the broker the required original identification documentation via the digital platform and this must be clearly sighted on screen.
- The broker must record details of the original identification documents sighted on the “Customer ID, Responsible Lending and Broker Declarations (Face-to-Face)” form and verify that the person’s details match the identification documents. The broker must also note on this form that Skype/FaceTime was used to identify the customer.
- The customer(s) must send the broker scanned copies of the identification documentation which must be sent to ME as part of the application submission.
If there are any doubts raised about the identity of the customer(s) either via the broker or as a result of our internal processes, further investigations will be required.
Verifying customer identity
Mystate continue to support remote VOI through the use of IDyou and Docusign both offered through MSA through this period
IDyou allows you to verify face-to-face via video using your mobile phone or device from any location. It takes only a few minutes; the customer enters their information, takes photos of their identity documents and signs a declaration. It’s then verified with a face to face call with you.
It’s secure and provides a compliant VOI system. It’s simple and at no cost.
This quick video clip will show you how.
Know Your Customer, Verification of Identity and Interview requirements during COVID-19
To accommodate the current Government-mandated restrictions around social distancing and COVID-19, we’ve made some changes to the way you need to meet NAB’s Know Your Customer (KYC) and Verification of Identity (VOI) requirements. Verification of Identity (VOI) is an Australian Registrars’ National Electronic Conveyancing Council (ARNECC) requirement to ensure that a person is who they claim to be.
To make it easier and safer for you and your customers, until further advised, you must now use the IDyou app to sight, collect and verify identity documents remotely for all applications submitted from this Thursday 23 April 2020.
In addition to using IDyou, it is a compulsory NAB requirement that you also interview your customer via video so you can sight them with their original documentation.
This is a temporary measure we’re implementing and one which meets the requirements of ARNECC, the Australian Transaction Reports and Analysis Centre (AUSTRAC) and NAB’s Anti-money Laundering Program.
Please note that this process is only applicable for consumer lending customers, not business lending. Business lending will have its own specific requirements.
Video interview requirements
You must schedule a video call between yourself and each individual customer to conduct your loan application interview, and to sight your customer with their original identity documentation. NAB requires a minimum of one photographic ID document, but preferably two.
You’ll need to review this ID document information in the video call and compare it to what your customer photographs and sends to you via the IDyou app.
To keep a record of the video interview process undertaken, you must provide notes in the summary tab in ApplyOnline. An example of what you might write is as follows:
I held a (describe the video method used e.g. Zoom, FaceTime etc.) interview on (insert date) and during this interview, the customer displayed their (insert ID sighted).
Important: We may call upon this information at a later date if it’s not provided in your summary notes.
Completing KYC & VOI using the IDyou app
IDyou, developed and powered by MSA National, allows you to collect identification documents and perform VOI via the IDyou app using the remote feature.
Getting started with IDyou and IDyou video meeting steps
- Download the IDyou app to your device from the applicable app store, then register for an account with MSA.
- Advise your customer that they’ll need to collate all the documentation they’ll need before your IDyou video meeting. These should be the same documents you saw in your earlier video interview.
- When you’re ready to start your video meeting and go to add a new verification in the app, make sure you select the ‘remote’ option - not ‘in person’.
During the IDyou video meeting
Guide your customer through the IDyou identification capture process by following these steps:
- Advise them that they’ll need to download the IDyou app on their device.
- To provide us with additional security around when and where the photos are taken, they’ll need to have their phone’s location services turned on.
- Initiate an invite via IDyou with your customer. They’ll then receive an invitation via email to conduct remote VOI.
- Upon log in, your customer will need to verify that their name and date of birth are correct, then take a selfie. Remind them to validate that the name provided is their full legal name.
- Your customer will need to add the relevant ID according to the list of options and then take a photo of their ID. Advise them they’ll need:
- an Australian passport or a foreign passport; and
- an Australian driver's licence or Proof of Age Card; and
- a marriage or change of name certificate, if necessary.
Note: The app lists additional documents that can be used where a passport is not held by the customer. We will only accept the additional non-photograph documents listed in the app.
6. They’ll then be required to provide a declaration and sign a third-party privacy consent via the app before you receive a completion email.
For the next steps, you must both be active in the IDyou app, with location services turned on:
- Initiate a video conference call by selecting 'Join Video Meeting'.
- During the call, use the 'Take photo' button to capture an image of the meeting. After you've done this, you can end your call.
- You’ll be asked to provide your declaration that the meeting occurred with the person whose name and details will be listed.
- You’ll then be provided with a security code within the app. This code will be required to download the report via a link which will be emailed to you.
- Provide the IDyou report with your application submission.
Please note: If you have any applications still in draft which will be submitted post-Thursday 23 April 2020, you’ll need to follow this process and provide a completed IDyou remote report along with your submission.
Using the Document Verification Service in ApplyOnline
When completing your application in ApplyOnline, you’ll still be required to use the Document Verification Service (DVS). If DVS is unsuccessful, you need to make further enquiry to satisfy the discrepancy. This may mean asking further questions or obtaining additional documents. The requirement to include the Customer Identity Check (CIC) form remains. There is no change to this process with the expansion of the IDyou remote function.
Completing declarations during this time
While the Broker Declaration, CIC form and system declarations make reference to sighting originals, we can confirm that by following the IDyou process outlined above, you’ll be complying with this requirement.
Loan application fraud – remaining vigilant
You're reminded to remain vigilant during this pandemic period and be aware of the heightened potential for loan application fraud. Should you suspect any potentially fraudulent or suspicious activity you should raise this with your BDM immediately.
For more information, please refer to these detailed user guides:
If you have any questions, take a look at these FAQs or get in touch with your BDM.
The Pepper team are all working hard to ensure we keep giving you the service you know and expect.
A few items that have been raised are around non-face to face identification and valuations. Pepper Money has provided the following clarification;
- Pepper Money will continue our business process of allowing non-face to face customer interactions with VOI identification via Zip ID or Australia Post. We are also working on digital verifications should the current VOI options become unavailable and will enact this immediately in need.
- Pepper is also working to provide a valuation solution should accessing securities become problematic. I will provide more details should we need to enact this change but rest assured this is well in hand.
Verification of ID
VOI of Clients
Our current BAU identification policy mandates the requirement for you, the broker, to verify a client’s identity face to face. Under the current situation, P&N will accept, until further notice, VOI options available via Australia Post locations. This allows you to complete client appointments using methods other than face to face (like Skype or FaceTime) where applicable.
Face-to-face appointments: Please ensure our standard Member Identification Certificate is completed in full where face-to-face appointments take place.
Remote Appointments: Please instruct your clients to attend an Australia Post locations to complete the VOI process.
Please note: It’s very important that your clients clearly advise Australia Post they are dealing with P&N Bank and not provide broker details (this is so Australia Post upload the completed form onto their VOI portal and our P&N team can access).
Resimac’s current policy already does not require face-to-face VOI. However, please note that Skype or similar does not qualify as face-to-face so, in those circumstances, Resimac’s non-face-to-face policy must be followed.
For the purposes of identification, the broker must receive original certified ID documentation and complete the ID form for a non-face-to-face interview (noting above with respect to Skype).
Remote Identification — IDYou
From 1 April 2020, Resimac will accept MSA National's IDYou Verification of Identity (VOI) mobile app for both face-to-face AND remote verification of a customer's identity. This move is aligned with the new guidelines recently released by ARNECC, to meet social distancing requirements.
IDYou is a secure tool that provides an assisted approach to capturing all VOI data ensuring the correct information is held and that the quality of information meets compliance standards.
Benefits to brokers and customers
- Improved privacy. No more hard copies in your briefcase and no more soft copies on your phone or laptop.
- It's quick! VOI in a matter of minutes.
- More secure: VOI documents are encrypted, stored on secure servers and requires a unique security code to access reports.
- Can be done anywhere, anytime.
Set-up access in two easy steps
MSA National will set you up with an account and email you the details.
- Download the app: Apple or Google Play
- Log in to the IDYou App using the username and password that will be emailed to you by MSA National over the next 48 hours.
Submitting the VOI report with your loan application
Once you have completed the VOI, it will automatically save the report on the IDYou App. When you are ready to submit your loan application to Resimac, you will need to go back into the IDYou App, go to that borrower's VOI record and click on 'Prepare Report for Lender' which then displays all lenders who are formally accepting IDYou.
In the context of government advice and regulations as a direct result of COVID-19, Suncorp is making the following process changes, effective Wednesday 8 April until further notice.
Verification of Identity (VOI) and KYC (Know Your Customer)
There are three main points to take away from this update:
- Customers can opt-in to this process if face-to-face is not available.
- VOI can be performed during the upfront application stage and not at the loan documentation/ mortgage execution stage.
- The verification process is temporarily allowing for virtual face-to-face.
Brokers can take the following steps:
- Broker to collect all KYC and VOI Verification documents from the customer prior to a virtual meeting and obtain consent to perform electronic verification in the absence of original/ certified documents (Note: Suncorp documentation requirements remain unchanged).
- Broker to complete the Non Face-to-Face Declaration document for the purposes of verification of KYC and VOI.
- A video conference is to be conducted with the customer and the broker is to take screenshots during the interview for verification purposes, which will be held on file by the broker. Brokers are obliged to seek consent from the customer to a) capture screenshots of the video interview and b) share the screenshots with Suncorp.
- Broker to validate all verification documents during the video interview with the customer including screenshots of each customer with each identification document and signing the application form during the interview.
- A screenshot of the technology used (i.e. Skype/Facetime/WhatsApp). Time, date stamp and length of the interview is to be recorded.
- The broker is required to record notes within the client interview guide to support their satisfaction of both their KYC and VOI requirements as noted above.
- All supporting notes and evidence to be submitted to Suncorp for review and storage, including screenshots.
- Please follow the existing ApplyOnline process to upload supporting documents. Ensure the linked forms are provided as separate documents, attached within supporting documents.
The linked forms are available on Business Partners Online
Teachers Mutual Bank Limited
Non Face to Face Interviews and associated identification (VOI) processes
Where a broker cannot meet directly with their clients in person, TMBL would like to remind its partners that there is an existing policy that enables brokers to conduct non-face to face meetings (for example by phone or a video conference facility such as Skype) supported by the capability for clients to be identified via either Australian Post Offices or ZipID.
VOI and Remote Interview Guide
Virgin Money Customer Identification Guidelines set out the collection and verification of customer identity information for all new customers.
In instances where brokers normal course of business requires remote identification and the customers are not meeting a broker in person at the same physical location, the below policy guideline will help to support your business.
The broker and customer must follow the instructions below for certified ID and video conferencing, all requirements must be met and documented correctly in order for the ID documents to be accepted.
- The customer must first provide the broker with original certified copies of their
- The ID must be certified by a permissible certifier only, refer to the list as per Certified ID
- The customer and the person certifying their ID will need to complete a Certified ID Form and the customer must submit this form to the broker together with the certified copies of ID documentation.
- The customer is to provide all completed documents to the broker in readiness for the identification
1. Once certified ID is received, the broker will complete an identification session with the customers using video - conferencing
During the video conference:
- The customer must display the originals of the photo identification documents used during the certified ID
- The broker must compare the certified ID documents to the originals displayed on the video conference by the individual being identified and
- Must take a screenshot/ photo of the individual holding at least one photo ID
- The screenshot must be in a quality that Virgin Money also to verify the ID documents used.
2. Broker to complete the broker declaration for video -conferencing identification which is contained within a designated section on the Certified Id.
3. All documents completed during the identification process must be submitted with the application at application lodgement stage and broker to document the details of the remote interview in the application submission
Full list of documents required are:
- Certified ID documents
- Certified ID form
- Screenshot of the applicant holding the ID during the identification session
Note: Please notify your BDM immediately, where there are any signs of tampering or amendments to the documents or where there are concerns as to the true identity of the applicants.
We understand that the spread of COVID-19 here in Australia is having an impact on brokers and their customers and we are continuing to monitor the situation and respond accordingly.
As part of this, we are currently making some changes to the Home Loan application process to help ensure we can continue to provide essential services to your network.
We know that Verification of Identity (VOI) remains a key concern and I wanted to let you know that we are revisiting our policies and procedures. In the meantime, the existing VOI policy will continue to apply and we will update you on any changes in due course.
Whilst that is occurring, and to provide immediate support, we are introducing an option for customer appointments to be held virtually.
From Wednesday 18 March 2020, brokers can conduct customer appointments virtually, using technology such as phone, video or teleconference. This is a permanent change.
What does this mean for a broker?
Where a broker is not able to meet the customer in-person, the customer appointment can be held virtually.
The mandatory process for virtual appointments is as follows:
- In ApplyOnline, in the comments section, the broker must note that the customer appointment has been completed virtually and specify the technology used.
Prior to submitting the loan application in ApplyOnline, the broker must obtain a copy of a completed and signed application form from the customer(s) – an email copy is acceptable.
From Monday 30 March additional changes have been made to the Electronic Verification and Verification of Identity process.
Customers will now be able to complete their Verification of Identity (VOI), Identity Verification (IDV) and Know Your Customers (KYC) requirements through alternative methods during the COVID-19 period and where a face-to-face meeting is unable to be conducted.
The key changes are:
- A new Electronic Verification process – we will require customers to go online and open a transaction account to meet IDV/KYC requirements
- A new Video Conference Verification of Identify (VoI) process – we will now allow video conference to replace face to face in the scenario where this is not possible
Key details for completing electronic verification of identity for new to bank customers:
As part of the broker's initial conversation with a customer who is new to Westpac, they will be able to ask a customer to consider opening a transaction account online in order to enable the customer to meet their IDV/KYC requirements without meeting anyone face to face.
- Customers will be directed to the brand-specific account opening page and advised to follow the simple online process to open the transaction account. In the case of joint home loan applications, each applicant will need to open their own Westpac Choice account to complete IDV/KYC.
- It is the customer’s decision as to whether they proceed to open an account to meet our KYC requirements.
- The monthly fee for this account will be waived for 12 months from the time of account opening, providing the broker emails WBCHomeLoanVirtualSupport@westpac.com.au or RRBHomeLoanVirtualSupport@westpac.com.au with this request. If your customer wishes to have the account closed the broker will also need to include this in their email.
Key details for completing Verification of Identity (VoI) via Video conference
Where a face to face VoI appointment cannot be completed we now have the option to complete VoI using Video Conference.
- There is a new VoI form specifically for VoI completed via video conference which will be housed online in the forms section.
- A screenshot must be taken of each applicant holding a form of photographic ID as well as screenshots of the identification documents required for each applicant.
- These screenshots must be scanned and along with the VoI form follow the standard procedures to send back to operations.
We will have links to:
- The new Video Conference VoI form
- A guide for opening a customer’s account
Please note: Training packs will be available in the secure portals for Westpac tomorrow and for RRB in 7 business days.