on 18-07-2018 03:01 PM
If you are acting under a Standing Authority CAF from your client with no expiry which was signed more than 2 years ago, do you still need to do a new VOI of that client every 2 years? The Rules seem unclear on this point and it would seem to defeat the purpose of having a non-expiring Standing Authority CAF if you do have to do another VOI while that CAF remains on foot (ie even though the CAF doesn't expire, the VOI exemption does).
We have several due to expire soon so appreciate an urgent response.
on 19-07-2018 04:50 PM
Thanks for your question @Brooke
ARNECC cover this in their MPR Guidance notes for VOI - Clause 5.6 namely
Previous verification of identity Where a verification of identity has occurred within the previous 2 years (either by applying the Verification of Identity Standard or some other way that constitutes reasonable steps), the person’s identity does not need to be verified again, provided the Subscriber takes reasonable steps to ensure they are dealing with the person who was previously identified. It is expected the Subscriber would review the evidence for the previous verification in order to be able to satisfy themselves that they are dealing with one and the same person.
We suggest best practice would be to renew the VOI every 2 years.
I hope that helps answer your query today
on 19-07-2018 05:00 PM
But the MPR Guidance referred to does not exactly address my initial query (ie although the CAF doesn't expire, does the VOI under that CAF expire so that you might as well treat the CAF as expired after 2 years?).
on 19-07-2018 05:36 PM
Since you are from WA you would likely know that VOI & CAF are two (2) separate requirements; VOI originated mainly from Landgate as a knee-jerk reaction to those fraudulent sales, whilst taking steps towards Identifying a client, while a Client Authorisation Form (CAF) is ARNECC extended requirement for use in E-settlement.
Depending on your client's frequency of e-settlement transactions, it may be better to adopt a procedural new CAF with every VOI. It wouldn't hurt to have more than one (1) valid CAF (standing or otherwise) even if done within the two (2) year period.
However some there might be circumstances where the use of the older Standing Authority CAF could be preferred.
Choice or options are a good thing to have.