Resolving discrepancies in client information

Managing discrepancies at the application stage

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.

Type of discrepancies

Discrepancies can be either material or immaterial.

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

Information that appears on a regulatory body search that is different from what’s been provided on an application
Signatures not matching
Inconsistent address details
Photographs that don’t appear to be of the same person.

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 through confirmation by yourself or the client where needed, whereas we may require additional documentation to resolve material discrepancies.

How discrepancies can arise

Here are some examples of how discrepancies can arise:

Discrepancy:	Example:
Information collected and information contained on a verification document.	A client's name or date of birth (DOB) on their passport is different to what has been provided in their application.
Information collected at different times in the client relationship is different.	The address collected for a client as part of a KYC refresh is different from what was provided for the client during the onboarding stage.
Information contained on different verification documents.	A client provides a driver licence and a passport with a different name or DOB.

How we manage discrepancies

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

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 (eg 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 (ie 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 (ie 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 license has already been provided.

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.

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