Resolving differences in client information

What happens if there’s a discrepancy in my client’s application?

A discrepancy is when there are differences in the information about the client provided at the onboarding stage or during the life of the relationship with the client.

Under our Anti Money Laundering and Counter Terrorism Financing (AML/CTF) regulatory requirements, we can’t open any accounts until any discrepancies are resolved. Given this, we recommended that you make reasonable attempts to identify and manage discrepancies at the application stage. If we identify an unresolved discrepancy, we may need to contact you or your client to resolve the discrepancy.

What’s the difference between material and immaterial discrepancies?

Material discrepancies are relating to information that appears as suspicious or fraudulent, for example:

Information that appears in a regulatory body search that doesn’t match what’s on the application
Signatures not matching
Inconsistent address details
Photographs that don’t appear to be of the same person.

We may request additional documentation to resolve material discrepancies.

Immaterial discrepancies generally relate to minor spelling errors or abbreviations, for example:

A postcode provided in an application doesn’t match the client’s driver licence
Spelling errors in a street name

Immaterial discrepancies can normally be resolved by you or your client confirming the details.

See below for some examples of how we resolve material and immaterial discrepancies. If there are discrepancies, we will follow up with you to confirm missing information which could either suspend accounts or delay applications from progressing.

How do discrepancies arise?

Here are some examples of how discrepancies can arise:

Discrepancy	Example
Information collected and information contained on a verification document.	Alice’s name or date of birth (DOB) on her passport is different to what she provided in her application.
Information collected at different times in the client relationship is different.	David’s address collected as part of a Know Your Client (KYC) refresh is different from what was provided on the original application.
Information contained on different verification documents.	Lin’s driver licence has a different name or DOB to her passport.

How do we resolve discrepancies?

Here are some examples of common discrepancies and what happens next:

Date of birth on application	Date of birth on driver licence	Action
14/09/1984	14/10/1984	As this would be considered a material discrepancy, we‘d require additional documentation to verify the client’s date of birth. This could, for example, be a certified birth certificate.

Name on application	Name on driver licence	Action
Christopher James Smith	Chris A Smith	Given the middle initial on the driver licence differs to the name provided on the application, this is considered a material discrepancy. In these scenarios, we’d require additional documentation to verify the correct name (e.g. a change of name certificate).
Christopher James Smith	Christopher J Smith	Given the initial 'J' matches the collected middle name, this is considered an immaterial discrepancy. In this scenario, we’d record the client’s full name, as per the application and no confirmation with the client/adviser is required.
Christopher James Smith	Christopher Smith	Given the driver licence does not present conflicted information (i.e. a different middle name), this is considered an immaterial discrepancy. In this scenario, we’d record the client’s full name, as per the application and no confirmation with the client/adviser is required.
Christopher James Smith	Chris J Smith	Given the driver licence doesn’t present conflicted information (i.e. a different middle name and first name), this is considered an immaterial discrepancy. In this scenario, we’d record the client’s full name as per the application and no confirmation with the client/adviser is required.
Christopher Smith	Christopher James Smith	Given the name on application does not contain the middle name, we’d be required to follow-up to re-collect the full name. We won’t need an additional verification document as a driver licence has already been provided.

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