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Does remote VOI pass the reasonable steps test?

sam makhoul sam makhoul
Sam Makhoul 6 minute read

VOI rules require that mortgage brokers take reasonable steps to verify the identity of their clients.

What constitutes reasonable steps is dependent on the circumstances of each individual case. However, in Schedule 8 of its Model Participation Rules, ARNECC has set out a Verification of Identity Standard which, if followed, is deemed to constitute reasonable steps (rule 6.5.6).

The VOI Standard requires:

  1. VOI to be conducted during a face-to-face in-person interview;
  2. That the verifier be satisfied that the person being identified is a reasonable likeness to the person depicted in photos on the identity documents; and
  3. That the identity documents provided meet one of the set out categories.

It is a common misconception that if you stray from the VOI Standard you are not taking ‘reasonable steps’.


Of course, it is advised to follow the VOI Standard whenever possible as it can provide safe harbour, however it is important to note that the VOI standard is not mandatory in situations where it is not possible to follow. There are circumstances in which a face-to-face in-person interview is not possible due to remoteness and in those cases, brokers can conduct VOI by taking other reasonable steps.

"ARNECC explicitly acknowledges this type of remote situation."

It provides a list of examples of further steps that can be taken, citing one example as "where the verification is unable to be conducted face-to-face due to remoteness conducting the verification by electronic means with further steps to satisfy yourself of the person’s identity." Refer to ARNECC Model Participation Rules Guidance, note 2 (page 5, 5.5 - Further Steps).

So what are the options for remote VOI?

Option 1: the Post Office


Brokers can send customers to their local Post Office. This is what most brokers are currently doing. The problem with this is long queues, delays and high cost of $44 per person per VOI.

Option 2: a courier service

Some companies are offering a courier service where the courier person conducts the VOI on behalf of the broker. But will customers feel comfortable handing over their ID to a complete stranger? A lot of the brokers I have spoken with are very apprehensive about this option.

Option 3: using a mobile app to conduct VOI electronically and remotely 

There are mobile apps that have a remote feature that allows brokers to complete the verification by electronic means on their iPhone or iPad. The client can securely send photos of the identity documents so the broker can assess whether they appear genuine. Once the broker has received sufficient identity documents, they then arrange a video call with the client during which they take a photo of them and can compare it to the documents to confirm likeness. Finally, the broker and client sign their respective declarations and create a VOI report that can be forwarded to any lender.

The bottom line

If you are in the digital camp you will find that using a mobile app to conduct VOI remotely is the best and most secure option after a face-to-face VOI.

Some lenders are getting very cute about scrutinising any solution that is digital, but the reality is that the current manual state of conducting VOI is fraught with security and privacy dangers. Brokers commonly complain about having hard copies of clients ID floating around their suit case and office as some don't have the storage space or security destruction facilities.

Worse still, there are brokers who are photographing and using generic apps to convert ID documents to PDF and are walking around with people’s ID documents on their camera roll! Most mobile apps do not store any information on the mobile phone or the app itself.

Whichever option you adopt, it is important to remember that even when the VOI Standard is followed, brokers must undertake further enquiries where doubt arises, or should reasonably have arisen (rule 6.5.3). As a guide, The Participation Rules require further steps to be taken, where:

  1. An identity document does not appear to be genuine;
  2. A photograph on an identity document is not a reasonable likeness;
  3. The person being identified does not appear to be the person to which the identity documents relate; or
  4. It is otherwise reasonable to take further steps.
Does remote VOI pass the reasonable steps test?
sam makhoul
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sam makhoul

Sam Makhoul

Sam Makhoul holds a Master of Laws degree (major in finance law) and is a director of MSA National, a law company specialising in mortgage processing. He has also advised and acted for the ‘who’s who’ of financial institutions and holds particular insight into the mortgage process developed and refined throughout his career. 


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