DMV's as an Indentity Bureau?

The traditional approach to identification at a motor vehicle agency in the pre-911 world was that DMV’s issued a driver’s license that was evidence that the holder met the minimum standards for the driver privilege. Identity verification was a necessary part of that process to prevent fraud and unauthorized people from obtaining a license. In short, motor vehicle departments generally saw and to a large degree still do see themselves as issuing driver’s licenses that are also used for identification.

The process for issuing a first time driver’s license involves presenting a set of documentation that proves who you are and where you live. The states often break this into primary and secondary forms of documentation. Examples of primary documentation include US Passport, expired or current state driver’s licenses, firearms permits, certain immigration documents, birth certificate etc. Examples of secondary documentation include home mortgage papers, life insurance policies, notarized tax returns, marriage/divorce certificates, non-US birth certificates etc. (See examples from the New York DMV http://www.nydmv.state.ny.us/idlicense.htm#idpoints) These documents are not verified for authenticity with the issuing agency except for half the states electronically verify Social Security Number and in some states electronically verify immigration status with the Bureau of Immigration. Only a few states retain copies or images of the source documents presented for identification. And, the person who performs all of the verifications is often an entry level counter clerk. Further, one has to only stop and consider what individuals who have just been through hurricane Katrina might have in the form of documentation readily available to them to realize that every one of these identification standards is flexible and can be adjusted as the need arises.

Compare this process with process that is used to actually issue a driver’s license. In every state if you haven’t been licensed before, you have to take a written examination and a practical examination in the form of a road test. (Note some states still require the written exam even if you are already licensed in another state.) The road test is usually administered by an “examiner”; in some states it is administered by a uniformed officer.

The contrast is apparent, motor vehicle departments are clearly more concerned about your ability to drive than identity. And probably rightly so as that is what their state legislation has told them to be concerned with. This isn’t to say they are not concerned with identity, but it is to say that probably no Motor Vehicle Departments enabling legislation makes them the “Department of Identity” giving them the authority and stature to function as such. Thus, it will take a major change to implement Real ID as this Act will put the identity validation process on at least equal if not greater footing than validating one’s ability to drive.

What will this mean to a Motor Vehicle Department and its constituents?

• Depending on whatever federal regulations are put in play, it is going to mean additional time and effort at the initial stage of obtaining a driver’s license and possibly the license renewal.
• How will “additional time” at the motor vehicle department play with the general public? Most DMV’s have gone to great lengths to encourage you not to come to the office, to keep lines short and generally remove the stigma that they have operated under for many years. Real ID, without additional resources (and probably resources better compensated than your average counter clerk) will probably increase the length of the lines.
• Will states consider having two types of licenses, one that is full service and can serve as a federally approved ID and another that is a valid license but doesn’t meet the id standard? Imagine if there were two lines, one where you wait longer but get the federally approved ID vs. the other where you just get the basic driver’s license.
• Or, will the Real ID act bring an end to the current on-line renewal of driver’s licenses?
• Will there be an opportunity for a commercial for-profit ‘trusted agent’ to perform identity verification as a value added service and submit verified identities to the DMV?
• What will states need to do to prevent internal fraud?—background checks, physical security of license materials and licensing employees.
• How do you educate the public to understand more complex identification requirements so they don’t have to make visits? If half of the people in the office have to make a return visit to complete the verification that is a 50% increase in volume.

Bottom line is either the motoring public has to be willing to wait much longer in line or states are going to have to spend significant on-going amounts of money supporting Motor Vehicle departments.

What do you think??? What do you prefer?