Jump to Content
ABA: The American Bankers Association
Skip Section Navigation

Are there DEI concerns around documentation required for name changes?

My bank is trying to determine if there are any diversity, equity, and inclusion (DEI) concerns related to the documentation the bank requires when customers change their name. Currently, the bank requires documents such as marriage certificates, court orders, divorce papers, and credit reports for customers, but the bank is concerned about potential DEI ramifications based on its current policy.

We reached out to Naomi Mercer, ABA’s Sr. VP for Diversity, Equity, & Inclusion, for assistance with this response. According to Naomi, the DEI implications are that transgender people frequently have issues with their legal name not matching the identity (and preferred name) to which they are transitioning.

Consistency is key. If the bank accepts a marriage license or court order or other federal or state ID for one person, it should accept the same for everyone. The bigger wrinkle may be an out-of-date photo on the ID (like a passport or driver’s license) and the transgender person’s current appearance.

Although not a specific resource for banks, this might help: https://transequality.org/documents

The bank can enter the state or states where the customer is located to understand what the requirements are for transgender people in the bank’s market. This resource is more for a transgender person seeking information, but might help bankers understand the legal requirements. (February 2021)

Compliance Hotline

Have a compliance-related question? We're here to help. Members, reach us by phone or email.