Verification of identity: individuals and sole proprietors

You need to verify the identification of a Client when creating a new Client . You are also required to verify the Client’s identity for any subsequent ownership changes for an account/policy/contract.

An information record must be created, and the Client's identity needs to be verified for the following products:

  • all universal and permanent life insurance products
  • all non-registered annuities (e.g. accumulation, payout)
  • all non-registered individual variable annuity contracts (segregated funds)
  • all non-registered mutual fund accounts
  • all non-registered Guaranteed Investment Certificates (GICs)

Each licensed advisor is responsible for personally verifying Client identity.

Advisors cannot verify their own identity. Advisors opening an account/policy/contract for themselves must have another licenced advisor complete their verification of identity. The details required to create the information record are collected on applications or forms.

Verifying the identity of an individual / sole proprietor

You can use one of the following methods to verify the identity of an individual:

  • Government-issued photo identification or
  • Dual process

For more information and examples of valid documents used to verify identity, visit the Instruction page for completion of Identity verification, third party determination and politically exposed persons (PEP) for individual owners (4830-I-E).

You can verify the identity of a person by referring to a government-issued photo identification document. This needs to be done in person, face-to-face.

The document must:

  • be authentic, valid and current,
  • be issued by a federal, provincial or territorial government (or by a foreign government if it is equivalent to a Canadian document);
  • indicate the person's name;
  • include a photo of the person;
  • include a unique identifying number; and
  • match the name and appearance of the person being identified.

Photo identification documents issued by municipal governments, Canadian or foreign, are not acceptable. Passports, driver’s licences, provincial photo ID cards and permanent resident cards are examples of acceptable government-issued photo identification documents.

You can determine whether a government-issued photo identification document is authentic, valid and current by viewing it in person., Review the characteristics of the original document and its security features (or markers, as applicable) with the Client you’re identifying. This will allow you to confirm that it is authentic, as issued by the government , valid (unaltered, not counterfeit) and current (not expired).   

It is not enough to only view a person and their government-issued photo identification document through a video conference or another type of virtual application.

Record keeping

If you use the government-issued photo identification method, you must record:

  • the person's name,
  • the date on which you verified the person's identity,
  • the type of document used (for example, driver's licence, passport, etc.),
  • the unique identifying number of the document used,
  • the jurisdiction (province or state) and country of issue of the document, and
  • the expiry date of the document, if available (if it appears on the document or card, you must record it).

The Dual Process method can be completed in person face-to face or non-face-to-face through video conference. This method requires you  to collect information from two different reliable sources that has any two of the following:

  • the person's name and address
  • the person’s name and date of birth,
  • the person's name and confirmation that they have a deposit account or other loan account

The information you refer to:

  • must be valid and current, and come from two different reliable sources.
  • can be found in statements, letters, certificates, forms, or other information sources.
  • can be provided through an original version or another version of original format such as a fax, a photocopy, a scan, or an electronic image
  • can not come from the same source. For example, you cannot use a bank statement from Bank A to confirm the person's name and address and another bank statement from Bank A to confirm the person's name and deposit account.

Here are some examples of how to enter dual process information on the 4830 form:

What is a reliable source of information?

A reliable source of information is an originator or issuer of information that you trust. To be considered reliable, the source should be well known and considered reputable. For example, a reliable source could be federal, provincial, territorial, or municipal levels of government, Crown corporations, federally regulated financial institutions, or utility providers.

Some examples of reliable sources include: Ontario ministry of transportation, Hydro One, Hydro Quebec, Société assurances automobile de Québec (SAAQ), Royal Bank, CIBC, Bell Canada, Telus Mobility.

Remember:

  • Social media is not an acceptable source of information to verify a person's identity.
  • The source cannot be the person whose identity is being verified, nor Sun Life, who is verifying identity.
  • Refer to the 4830-I for a table of examples of reliable sources of information for the dual-process method.

Can I use a government-issued photo identification document when using the dual process method via video conference?

Yes, a government-issued photo identification document can be used to verify a Client's name and address (e.g. driver’s license). It’s also acceptable to verify the Client's name and date of birth with a copy of a different government-issued photo identification document (e.g. a Canadian passport).

Remember, there’s a requirement that the information must be from two different sources. If you choose to refer to two pieces of government issued-photo identification issued by the same level of government, you must ensure that each piece is issued by a different department, ministry, or office.

Do I need to send in copies of source documents when using the dual process method?

No, not if you’ve reviewed the source documents in person or through video conference.

**Note: If the information on the document does not match the information provided by the person, you cannot rely on it. For example, it is not acceptable to rely on information if the reference number associated with the information is incomplete or redacted.

Record keeping requirements

If you use the Dual Process method, you must record:

  • the person's name;
  • the date the information was verified;
  • the name/issuer of the two different reliable sources that were used;
  • the type of source document used to (for example, utility statement, bank statement, marriage licence); and
  • the number associated with the source document(for example, account number or if there is no account number, a number that is associated with the information, which could be a reference number or certificate number, etc.).