Real ID Planning Project

Maryland Department of Transportation, Motor Vehicle Administration      

Real ID Act Planning Project TORFP/Project Requirements/NPRM Traceability Analysis
     

 

 

Version 1.0 NOVEMBER 9, 2007

PREPARED BY:
SOFTWARE PERFORMANCE SYSTEMS, INC. 7905 MALCOLM ROAD   CLINTON, MD 20735

Document Change History
Date November 8, 2007 November 9, 2007 Version no. 0.1 1.0 Description of Change Submitted to MVA Author SPS SPS

1 1.1

INTRODUCTION Purpose The purpose of this task is to analyze the three sets of requirements involved in the Real ID Planning Project. This document shows the traceability interactions among the TORFP Requirements, Project Requirements, and NPRM requirements.

1.2

General Assumptions • The Project Requirements list includes all NPRM Requirements, selected TORFP requirements, and several other initiated by MVA outside the TORFP scope.

1.3

Presentation limitations The scope of this document is limited to: • • There are “one-to-many” and “many-to-many” relationships between the projects scope, so the traceability dependency cannot be presented in one table. The requirements dependencies offered in this document are the exact image of the CaliberRM structures and traceability.

Real ID Requirements Traceability Analysis      

   

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2 2.1
#

TORFP TRACEABILITY TABLE Legend
TORFP requirement numbering. NPRM requirements are presented by the reference to the paragraphs in the NPRM document. Project Requirements are presented by their numbers

Sec.II, B (example) CA1 (example)

2.2

TORFP Traceability Table.
Requirements

#
Capture the Full Legal Name in the Driver Licensing System (DLS) by modifying the NAME field size to equal the American Association of Motor Vehicle Administrators (AAMVA) standard in force at the time of application development. The current AAMVA standard is 125 characters – 40 characters each for first, middle and last names and 5 characters for suffix. Evaluate and provide recommendations to modify the DLS application and databases to accommodate increased name field. Evaluate and provide recommendations for maintaining a single demographic database for all business applications.

NPRM

Project Reject

a

Sec. II.H.1 6 CFR Part 37

CA1

a1

Sec. II.H.1 6 CFR Part 37

CA1

a2

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Requirements #
Evaluate and provide recommendations for application of the same identity standards (Real ID Act Std.) to all business applications. Evaluate and provide recommendations to determine legislative changes required.

NPRM

Project Reject

a3

a4
Evaluate and provide recommendations for segregating demographic databases for DLS and all other business systems.

a5

a6 b

Evaluate and provide recommendations for discrepancy, precedence, synchronization and other issues between databases.

Integrate the following new or modified features into the DL and ID cards:

Sec. II.H.1 6 CFR Part 37

CA1, CA2, CA3,CA4, CA6,CA6, CA7, CA8

b1

Full Legal Name - Evaluate and provide recommendations to modify all card layouts to accommodate full legal name.

Sec. II.H.1 6 CFR Part 37

CA1

b2

Person’s Address of Principal Residence – Evaluate and provide recommendations to modify DLS application to print principle residence address of CDL drivers on card. CDL currently uses mailing address on card. MD Legislative changes are required to place residence address on CDL card.

6 CFR Part 37 § 37.17 . (f)

CA6

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Requirements # b3
Physical card security features to prevent tampering, counterfeiting or duplication. – Evaluate and provide recommendations to modify card layout and DLS applications to accommodate future standards for AAMVA hologram and level 3 security features.

NPRM

Project Reject

§ 37.15, § 37.19

CA8, CA9

b4

Common Machine Readable Technology – Evaluate and provide recommendations to modify card layout and DLS application to utilize future specified technology, data and encryption. New card requirements for compliance with DHS standards.

§ 37.19

CA9

b5

Sec. II.H.1 6 CFR Part 37, § 37.17 . (f)
Develop temporary DL/ID cards with expiration of card coinciding with the end of permitted stay or issuance for no more than 1 year.

CA1, CA2, CA3,CA4, CA6,CA6, CA7, CA8

c

c1

Evaluate and provide recommendations to modify DLS application to allow user definable expiration date on temporary cards. MD legislation will be required in order to tie the expiration date to the end date of permitted stay. Evaluate and provide recommendations to modify card design to indicate that it is a temporary document with a “different than usual” expiration date.

Sec. II. G

TE2

c2

Sec. II. G

TE2

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Requirements # d
Establish electronic interfaces to identity document and status issuance sources for verification of customer identity documents and integrate into DLS application.

NPRM

Project Reject

d1

d2

Social Security Number Non-eligibility Letter - Evaluate and provide recommendations to modify DLS application eligibility check to interface with American Association of Motor Vehicle Administrators (AAMVA) interface to Social Security MVA (SSA). Assumes AAMVA interface to SSA exists and that SSA will provide verification. Federal Immigration Status – Evaluate and provide recommendations to modify DLS application eligibility check to interface with the Dept of Homeland Security (DHS) Systematic Alien Verification System for entitlements (SAVE).

d3

Military Status and Identity Verification - Evaluate and provide recommendations to modify DLS application eligibility check to interface with the Department of Defense - Defense Enrollment Eligibility Reporting System (DEERS) Birth Certificate: Evaluate and provide recommendations to modify DLS application eligibility check to interface with AAMVA interface to the National Association for Public Health Statistics (NAPHSIS) / State Vital Record Agencies. Primary Residence Address Verification - Evaluate and provide recommendations to modify DLS application eligibility check to interface with Third Party Providers for address verification. i. Third Party Providers – Assumes future federal regulation will allow third party providers to verify certain data and that interfaces can be implemented.

d4

d5

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Requirements # d6
Miscellaneous Verifications with Other Jurisdictions Evaluate and provide recommendations to modify DLS application eligibility check to interface with other jurisdictions to: i.Verify that a SSN is not duplicated on a DL / ID account in another state by a different person. Develop process for resolving discrepancies. ii.Verify that the person does not have an active DL / ID in any other state. Develop process for requesting termination of DL/ID in original jurisdiction upon issuance to DL/ID in the new jurisdiction. iii.Integrate “ID Check” software and hardware into DLS application for scanning and capture of data on DL and ID cards from other jurisdictions. iv.Verify all other data pertinent to DL and ID cars issuance by MVA. General Manual Verification – Evaluate and provide recommendations for manual verification options and processes where electronic interfaces are not available or feasible. Capture digital images of identity source documents so that images can be retained in electronic storage in a transferable format.

NPRM

Project Reject

d7

Sec. II. E.2.a, F

VE1, VE2, VE3, EX2, EX3

e

Sec. II.H.1 6 CFR Part 37

SY4, SY5, SY8, SY10

e1

Evaluate and provide recommendations to modify DLS application to require capture of additional scanned documents.

Sec. II.H.1 6 CFR Part 37

SY4, SY5, SY6,SY7, SY8, SY10

e2

Evaluate and provide recommendations to develop DLS interface to Foster Freeman Document Comparator for image capture.

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Requirements #
Evaluate and provide recommendations to create application to transmit document images to other agencies and jurisdictions.

NPRM

Project Reject

e3

Sec. II.H.1 6 CFR Part 37

SY12,

e4 f

Evaluate and provide recommendations to develop legislation to enable transmission of data and documents to other agencies depending on regulatory requirements.

Sec. II.H.1 6 CFR Part 37

SY12,

Retain images of source documents presented for a minimum of 10 years.

Sec. II.H.1 6 CFR Part 37

SY10

f1

Evaluate and provide recommendations to develop a document/data lifecycle plan for DLS document images and data and current and future storage capacity requirements.

Sec. II.K.1 Sec. II.K.5 Sec. III. Sec. II.K.1 Sec. II.K.5 Sec. III. Sec. II.I.2, 4 Sec. II.K.1 Sec. II.K.5 Sec. III. Sec. II.K.1 Sec. II.K.5 Sec. III.

CE1

Establish an effective procedure to confirm or verify a renewing applicant’s information.

g
Evaluate and provide recommendations to modify DLS to include indicators signifying that certain data and / or documents have been verified and validated.

CE1, EX1, RE1, RE2, RE3, RE4, TE3, TE4, VE2

g1

CE1

Evaluate and provide recommendations to create required audit trail indicators for verified and validated data.

g2

CE1

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Requirements # h
Ensure physical security of locations where DL/ID cards are produced.

NPRM

Project Reject

Sec. II.K.1 h1
Evaluate and provide recommendations to determine and document required procedures and physical / electronic security measures for distributed card productions at MVA branch offices; MVA centralized production and outsourced centralized production. Subject all person’s authorized to manufacture or produce DL/ID cards to appropriate security clearance requirements.

SE1

Sec. II.K.1

SE1, SE5

i

Sec. II.K.1

SE3, SE4, SE5, SE6

i1

Evaluate and provide recommendations to determine and document security clearance requirements for persons authorized to manufacture or produce cards at MVA branch offices, MVA centralized production and outsourced centralized production. Evaluate and provide recommendations to develop legislation authorizing MVA to conduct certain types of security checks.

Sec. II.K.1

SE3, SE4, SE6

i2 j
Establish fraudulent document recognition training programs for appropriate employees engaged in the issuance of DL/ID cards.

Sec. II.K.1

SE3, SE6

Sec. II.K.1

SE2

j1

Evaluate and provide recommendations to determine and document training needs for all employees engaged in the issuance of cards.

Sec. II.K.1

SE2

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Requirements # j2
Evaluate and provide recommendations to determine requirements, develop and deliver curriculum for fraudulent document recognition training.

NPRM

Project Reject

Sec. II.K.1

SE2

k

Limit period of validity of DL/ID cards that are issued to military license holders who are stationed outside of Maryland to a period not exceeding 8 years.

Sec. II.G, H.3

PR5, RE2

Evaluate and provide recommendations to modify DLS application to limit period of validity.

k1
Evaluate and provide recommendations to develop legislation required limiting the validity period.

Sec. II.G, H.3

PR5, RE2

k2 l
Determine business rules, processes, DLS modifications and card designs (DL / ID / Driving Certificate) required assuming that Maryland will NOT REQUIRE Legal Presence for the issuance of DL / ID cards. Evaluate and provide recommendations to develop legislation for this requirement.

Sec. II.G, H.3

PR5, RE2

II.D.1, Sec. II.G

DO3, TE1

l1

m

Determine business rules, processes, DLS modifications and card designs (DL / ID) required assuming that Maryland WILL REQUIRE Legal Presence for the issuance of DL / ID cards.

II.D.1, Sec. II.G

DO3, TE1

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Requirements #
Evaluate and provide recommendations to develop legislation for this requirement.

NPRM

Project Reject

m1 n
Provide electronic access to all other states to information contained in the motor vehicle database of the state.

Sec. II.C.1.a Sec. II.K.5

SY11, SY12

n1

Evaluate and provide recommendations to determine requirements for allowing access to MVA databases by other agencies and jurisdictions.

Sec. II.C.1.a Sec. II.K.5

SY11, SY12

n2

Evaluate and provide recommendations to develop and implement a data / image exchange server and database separate from the production environment.

Sec. II.C.1.a Sec. II.K.5

SY7, SY11, SY12

Maintain a database that contains at a minimum:

o
Evaluate and provide recommendations to include all data fields printed on DL/ID cards.

Sec. II.J

SY1

o1
Evaluate and provide recommendations to include driver histories, including motor vehicle violations, suspensions and points on licenses.

Sec. II.J

SY1

o2

Sec. II.J

SY1

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Requirements #
Evaluate and provide recommendations for modifications to the DLS application and the DLS databases.

NPRM

Project Reject

o3 p

Evaluate and provide recommendations for utilization of 3rd party providers for: Validation and verification of identifying documents.

p1

p2

Performing all DL and ID services currently performed in an MVA branch office. Performing background / security clearance checks on current and new DL and ID personnel (contractor and MVA employed).

p3

q

Develop and document business processes and procedures for issuance of duplicates (replacements) and corrections to DL and ID cards to include: 1) Change of address, 2) Change of name, 3) Change of other information, 4) Duplicate (replacement) issuance Develop and document business processes and procedures for issuance of duplicates (replacements) and corrections to DL and ID cards to include Change of address

Sec II, H.6

PR3

q1

Sec II, H.6

PR3

q2

Develop and document business processes and procedures for issuance of duplicates (replacements) and corrections to DL and ID cards to include Change of name

Sec II, H.6

PR3

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Requirements #
Develop and document business processes and procedures for issuance of duplicates (replacements) and corrections to DL and ID cards to include Change of other information

NPRM

Project Reject

q3

Sec II, H.6

PR3

q4 r

Develop and document business processes and procedures for issuance of duplicates (replacements) and corrections to DL and ID cards to include Duplicate (replacement) issuance

Sec II, H.6

PR3

Evaluate and provide recommendations for DLS application changes for issuance of duplicates (replacement) and corrections to DL and ID cards to include: 1) Change of address, 2) Change of name, 3) Change of other information, 4) Duplicate (replacement) issuance DLS application changes for issuance of duplicates (replacement) and corrections to DL and ID cards to include Change of address

Sec.II, B

SY3

r1

Sec.II, B

SY3

r2

DLS application changes for issuance of duplicates (replacement) and corrections to DL and ID cards to include Change of name

Sec.II, B

SY3

r3

DLS application changes for issuance of duplicates (replacement) and corrections to DL and ID cards to include Change of other information

Sec.II, B

SY3

r4

DLS application changes for issuance of duplicates (replacement) and corrections to DL and ID cards to include Duplicate (replacement) issuance

Sec.II, B

SY3

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Requirements #
Evaluate and provide recommendations for utilization of 3rd party providers for: 1) Central issuance of DL and ID cards, 2) Non-Commercial Driver License Law Testing, 3) Non-Commercial Driver License Skills Testing, 4) Development of legislative changes needed to allow 3rd party provider law and skills testing.

NPRM

Project Reject

s

PR2

Utilization of 3rd party providers for Central issuance of DL and ID cards

s1
Utilization of 3rd party providers for Non-Commercial Driver License Law Testing

PR2

s2
Utilization of 3rd party providers for Non-Commercial Driver License Skills Testing

s3
Utilization of 3rd party providers for Development of legislative changes needed to allow 3rd party provider law and skills testing.

s4 t

Evaluate and provide recommendations to modify DLS application and databases to allow capture of customer residence and mailing addresses.

CA6, SY2

u

Evaluate and provide recommendations to replace Soundex Number with a unique, permanent Customer Account Number in DLS and all other business applications.

Real ID Requirements Traceability Analysis      

   

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Requirements # v
Evaluate and provide recommendations to develop Biometric Customer Identification for: 1) Facial Recognition, 2) Finger Scan. 3) Iris Scan, 4) Legislative changes to allow biometric identification Biometric Customer Identification for Facial Recognition

NPRM

Project Reject

v1

Subpart D,§ 37.41 v2
Biometric Customer Identification for Finger Scan

PR8

Subpart D,§ 37.41 v3
Biometric Customer Identification for Iris Scan

PR8

v4

Legislative changes to allow biometric identification

w

Evaluate and provide recommendations for: 1) Waiver of vision certification for all DL renewals up to age 40, 2) Waiver of vision certification for all DL renewals that are currently restricted with corrective lenses, 3) Waiver of vision certification for DL renewals above age 40 every other renewal period, 4) Legislative changes needed to allow waiver of any vision requirements. Waiver of vision certification for all DL renewals up to age 40

w1

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Requirements #
Waiver of vision certification for all DL renewals that are currently restricted with corrective lenses

NPRM

Project Reject

w2
Waiver of vision certification for DL renewals above age 40 every other renewal period

w3
Legislative changes needed to allow waiver of any vision requirements.

w4 x
Evaluate and provide recommendations for: 1) ID card renewals, 2) Legislative changes to allow renewal of ID cards.

§ 37.23

RE5

x1

ID card renewals

§ 37.23
Legislative changes to allow renewal of ID cards.

RE5

x2

y

Evaluate and provide recommendations to develop modules for the MVA e-commerce (eMVA) and mail-in applications to allow: 1) Corrected DL and ID cards, 2) Duplicate (replacement) DL and ID card order, 3) Business and Salesman license renewals, corrections and duplicates (replacements), 4) eMVA to interface with the point of sale (POS) system for all payment

Real ID Requirements Traceability Analysis      

   

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Requirements #
processing.

NPRM

Project Reject

Modules for the MVA e-commerce (eMVA) and mail-in applications to allow Corrected DL and ID cards

y1
Modules for the MVA e-commerce (eMVA) and mail-in applications to allow Duplicate (replacement) DL and ID card order

y2

y3

Modules for the MVA e-commerce (eMVA) and mail-in applications to allow Business and Salesman license renewals, corrections and duplicates (replacements)

y4 z

Modules for the MVA e-commerce (eMVA) and mail-in applications to allow eMVA to interface with the point of sale (POS) system for all payment processing.

z1

Evaluate and provide recommendations for: 1) Redistributing driver license renewals evenly over the 5-year cycle, 2) Legislative changes needed to allow renewal periods that are less than or greater than 5 years. Redistributing driver license renewals evenly over the 5-year cycle

Real ID Requirements Traceability Analysis      

   

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Requirements # z2
Legislative changes needed to allow renewal periods that are less than or greater than 5 years.

NPRM

Project Reject

aa

Evaluate and provide recommendations for: 1) Eliminating the Employer Name step in the DLS application from all non-commercial DL flows, 2) Legislative changes needed to allow elimination of this step. (ref. law section 16-106.a.1) Eliminating the Employer Name step in the DLS application from all non-commercial DL flows

aa1
Legislative changes needed to allow elimination of this step. (ref. law section 16-106.a.1)

aa2 bb
Evaluate and provide recommendations to implement Check 21 paperless check processing in POS system.

Real ID Requirements Traceability Analysis      

   

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3 3.1

PROJECT REQUIREMENTS Legend
Originated Outside NPRM and TORFP

CA10

CE7

Exclusively NPRM ORIGINATED

SY9 Sec.II, B (example) M.a1

Exclusively TORFP ORIGINATED NPRM requirements are presented by the reference to the paragraphs in the NPRM document. TORFP

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3.2
#

Project Requirements Traceability Table
Project Requirements
Full Legal Name State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: The person's full legal name. - For the full legal name placed on the face of the driver’s license or identification card, DHS is proposing to adopt the ICAO 9303 Standard...the standard requires Roman alphabet characters, allows a total of 39 characters on the face of the driver’s license or identification card, and provides standards for truncation of longer names.

NPRM

TORFP

CA1

Sec. II.H.1 6 CFR Part 37

M.a M.a1 M.b1 M.b5

CA2

Date Of Birth State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: The person's date of birth. Gender State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: The person's gender. Driver's License Or Identification Card Number State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: The person's driver's license or identification card number. Digital Photograph State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: A digital photograph of the person. - DHS is proposing that digital photographs comply with current ICAO 9303 standards.

Sec. II.H.2 6 CFR Part 37

M.b5

CA3

Sec 202 c (1) (a) Sec. II.H.3

M.b5

CA4

Sec 202 (b) (3), Sec II, H.1

M.b5

CA5

Sec 202 (b) (4), Sec II, H.5

M.b5

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#

Project Requirements
Address Of Principle Residence State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: The person's address of principle residence.

NPRM

TORFP M.b2 M.b5 M.t

CA6

Sec 202c (1) (D), Sec II, H.6

CA7

Signature State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: The person's signature. Physical Security Features State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: Physical security features designed to prevent tampering, counterfeiting, or duplication of the document for fraudulent purposes. M.b3 M.b5 Machine-Readable Technology State shall include, at a minimum, the following information and features on each driver's license and identification card issued to a person by the State: A common machine-readable technology, with defined minimum data elements. - The proposed regulation mandates the use of the PDF–417 2D bar code as the common Machine Readable Technology standard and to adopt most of the mandatory data elements described in the 2005 AAMVA Driver’s License/Identification Card Design Specifications, Annex D, as its MRT data elements model. - DHS proposes the 2D bar code as the option for Machine Readable Technology. - DHS proposes that States consider storing in the machine readable zone (MRZ) only the minimum data elements necessary for the purpose for which the REAL IDs will be used. Indicate Compliance Modify card design to indicate by visual means that a REAL ID driver’s license and identification card is compliant.

Sec II, H.7

M.b5

CA8

Sec II, H.8

M.b3

CA9

Sec. II.H.8 6 CFR Part 37

M.b3 M.b4 M.b5

CA10

Real ID Requirements Traceability Analysis      

   

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#

Project Requirements
Indicate Non-Compliance Non-Real ID DL/ID: In any case in which the State issues a driver's license or identification card that is not Real ID compliant, ensure that such license or identification card--(A) clearly states on its face that it may not be accepted by any Federal agency for federal identification or any other official purpose; and (B) uses a unique design or color indicator to alert Federal agency and other law enforcement personnel that it may not be accepted for any such purpose. . State Certification States must demonstrate initial compliance with these regulations by submitting a certification and certain specified documents including a description of its REAL ID program, and demonstrate continued compliance by annually submitting such certification and documents. - States shall be required to describe standards and procedures for managing driver records and data collected, stored, modified, accessed and transmitted under the requirements of this rule. -States shall document procedures for resolving data formatting, quality, and integrity issues. DHS encourages States to draft collective standards and best practices for the management of both documents and data required under the provisions of this rule. - States shall describe procedures to prevent unauthorized access to, or dissemination of, images of documents provided by applicants, stored pursuant to the Act. States shall also detail procedures for document retention and destruction for both physical and electronic records.

NPRM

TORFP

CA11

CE1

Sec. II.K.1 Sec. II.K.5 Sec. III. State Certification

M.f1 M.g1 M.g2

CE2

Certification Package Submission Each State shall submit its certification package to DHS on its REAL ID driver’s license and identification card programs no later than February 10, 2008, 90 days before the May 11, 2008 compliance date required under the Act. DHS strongly encourages States to communicate their intent to certify compliance or request an extension by October 1, 2007.

Sec. II.B.(1) Sec. II.B.(3)

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#

Project Requirements
Certification Package Submission Each State shall submit its certification package to DHS on its REAL ID driver’s license and identification card programs no later than February 10, 2008, 90 days before the May 11, 2008 compliance date required under the Act. DHS strongly encourages States to communicate their intent to certify compliance or request an extension by October 1, 2007.

NPRM

TORFP

CE3

Sec. II.B.(1) Sec. II.B.(3)

CE4

Extension Request The State shall request an extension of the certification deadline based on the lack of a final REAL ID rule by filing such a request no later than October 1, 2007. Comprehensive Security Plan (CSP) State shall prepare a comprehensive security plan for its offices and driver’s license storage and production facilities, databases, and systems utilized for collecting, disseminating or storing information used in the issuance of REAL ID licenses. Annual Certification States shall resubmit plans on an annual basis until all requirements of the rules are met. Quarterly Reports Paperwork Reduction Act -- States will also submit quarterly reports analyzing their use of the exceptions process and monitoring security Required Documentation State shall require, at a minimum, presentation and verification of the following information before issuing a driver's license or identification card to a person: - A photo identity document, except that a non-photo identity document is acceptable if it includes both the person's full legal name and date of birth. - Documentation showing the person's date of birth. - Documentation showing the person's name and address of principal residence. - Proof of the person's social security account number or verification that the person is not eligible for a social security account number.

Sec. II.B.(2) Sec. II.B.(3)

CE5

Sec. II.C.1.a

M.h M.h1

CE6

Sec. II.B.(3)

CE7

Sec. VII.A

DO1

Sec. II.D.2.a Sec. II.D.2.b Sec. II.D.2.c Sec. II.E.5

M.d7

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#

Project Requirements
Identity Documentation State shall require the following documents to establish identity for purposes of this regulation: A valid unexpired U.S. passport; A certified copy of a birth certificate; A consular report of birth abroad; An unexpired permanent resident card; An unexpired employment authorization document (EAD); An unexpired foreign passport with valid U.S. visa affixed; A U.S. certificate of citizenship; A U.S. certificate of naturalization; or A REAL ID driver’s license or identification card issued subsequent to the standards established by this regulation

NPRM

TORFP

DO2

II.D.1

DO3

Lawful Presence Documentation State shall require, before issuing a driver's license or identification card to a person, valid documentary evidence that the person-- (i) is a citizen or national of the United States; (ii) is an alien lawfully admitted for permanent or temporary residence in the United States; (iii) has conditional permanent resident status in the United States; (iv) has an approved application for asylum in the United States or has entered into the United States in refugee status; (iv) has an approved application for asylum in the United States or has entered into the United States in refugee status; (v) has a valid, unexpired nonimmigrant visa or nonimmigrant visa status for entry into the United States; (vi) has a pending application for asylum in the United States; (vii) has a pending or approved application for temporary protected status in the United States; (viii) has approved deferred action status; or (ix) has a pending application for adjustment of status to that of an alien lawfully admitted for permanent residence in the United States or conditional permanent resident status in the United States.

II.D.1

M.l M.m

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#

Project Requirements
Exceptions Processing for Extraordinary Circumstances Where a State chooses to establish an exceptions process, that process must include, at a minimum, the driver record maintained by the DMV must indicate when an alternate document is accepted; any driver’s license or identification card issued using exceptions processing requires a complete record of the transaction, including a full explanation of the reason for the exception, alternative documents accepted and how applicable information from the document was verified; the jurisdiction retains the alternate documents accepted or copies thereof in the same manner as for other source documents as described in section II.J. and provides these upon request to DHS for audit review. Duplicate SSN Confirm with the Social Security Administration a social security account number presented by a person using the full social security account number. In the event that a social security account number is already registered to or associated with another person to which any State has issued a driver's license or identification card, the State shall resolve the discrepancy and take appropriate action.

NPRM

TORFP

EX1

Sec. II.F

M.g

EX2

Sec. II. E.2.a, F

M.d7

EX3

Persons born before 1935 Individuals born before January 1, 1935, may be unable to produce birth certificates, or States may be unable to verify any birth certificates produced by such individuals. Such cases should not preclude persons from obtaining a REAL ID driver’s license or identification card, but should be handled according to the State’s exceptions process. No Fixed Address For individuals who have no fixed address, DHS believes that each State should continue to address these situations through a written and documented exceptions process.

Sec. II.E.2.a Sec. II.F

M.d7

EX4

Sec. II.H.4

Real ID Requirements Traceability Analysis      

   

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Project Requirements
Real ID Issuance Deadline Driver’s licenses and identification cards issued before May 11, 2008 that do not expire until after the phase-in period ends must be exchanged for driver’s licenses and identification cards issued under the new rules in order to be accepted by Federal agencies for official purposes after May 10, 2013.

NPRM

TORFP

PR1

II.B.(3)

PR2

Central Issuance Utilize 3rd party providers for Central issuance of DL and ID cards Duplicates and Corrections Develop and document business processes and procedures for issuance of duplicates (replacements) and corrections to DL and ID cards to include Change of name, change of address, change of other information, and duplicate issuance

M.s M.s1 M.q M.q1 M.q2 M.q3 M.q4

PR3

Sec II, H.6

PR4

PR5

Out of State Refuse to issue a driver's license or identification card to a person holding a driver's license issued by another State without confirmation that the person is terminating or has terminated the driver's license. Period of Validity Limit the period of validity of all driver's licenses and identification cards that are not temporary to a period that does not exceed 8 years. Records of Suspected Fraud If a driver’s license or identification card is not issued because of suspected fraud, the record should be maintained for ten years and reflect that a driver’s license or identification card was not issued for that purpose Facial Image Capture Subject each person applying for a driver's license or identification card to mandatory facial image capture

6 CFR Part 37

M d7

Sec. II.G

M.k M.k1 M.k2

PR6

Sec. II.H.3

PR7

Subpart B, § 37.11

Real ID Requirements Traceability Analysis      

   

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Project Requirements
Biometrics Evaluate and provide recommendations to develop Biometric Customer Identification for: 1) Facial Recognition, 2) Finger Scan.

NPRM Subpart D,§ 37.41

TORFP M.v1 M.v2

PR8

RE1

Verify Renewal Information Establish an effective procedure to confirm or verify a renewing applicant's information. In-Person Renewal Period

Sec. II.I.2

M.d7 M.g M.g M.k1 M.k2

RE2
Re-verification for In-Person Renewals The States must re-verify original information and source documents used as the basis for issuance of the original REAL ID driver’s license or identification card, but the individual need not resubmit documents for verification as long as the State has retained copies of source documents for the period of renewal. Re-verification for Remote/Non In-Person Renewals The State must re-verify information on the source documents that were used as the basis for issuing the original REAL ID driver’s license or identification card, to assure there is no match against death information recorded with either the State vital statistics offices or SSA. ID Card Renewals Institute renewals for ID cards Physical Security Ensure the physical security of locations where drivers' licenses and identification cards are produced and the security of document materials and papers from which drivers' licenses and identification cards are produced.

Sec. II.I.2

RE3

Sec. II.I.2

M.g M.d7

RE4

Sec. II.I.1

M.g

RE5

Sec. II.I.2

M.x M.x2

SE1

Sec. II.K

M.h M.h1

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Project Requirements
Fraudulent Document Recognition Training Establish fraudulent document recognition training programs for appropriate employees engaged in the issuance of drivers' licenses and identification cards. Background Checks for Covered Personnel Subject all persons authorized to manufacture or produce drivers' licenses and identification cards to appropriate security clearance requirements.

NPRM Subpart D, § 37.41

TORFP M.j M.j1 M.j2

SE2

SE3

Sec. II.K.1

M.i M.i1 M.i2

SE4

Criminal Background Checks The regulations propose that States collect fingerprints for individuals who seek employment in a covered position, in order to conduct a criminal history record check (CHRC) on those individuals through the Federal Bureau of Investigation (FBI) and State repositories. Background Check Waivers States may grant waivers allowing individuals to maintain their positions under particular circumstances as authorized by the States; DHS proposes that States adopt written practices for waiver processes and provide them to DHS as part of the State’s comprehensive security plan. Financial History Checks DHS is proposing that the States perform a financial history check on individuals seeking employment in covered positions. Outsourcing Background Checks Evaluate and provide recommendations for utilization of 3rd party providers for performing background / security clearance checks on current and new DL and ID personnel (contractor and MVA employed).

Sec. II.K.1

M.i M.i1

SE5

Sec. II.K.1

M.h1 M.i

SE6

Sec. II.K.1

M.i M.i1 M.i2

SE7

M.p3

Real ID Requirements Traceability Analysis      

   

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Project Requirements
Motor Vehicle Database Maintain a State motor vehicle database that contains, at a minimum -- (A) all data fields printed on drivers' licenses and identification cards issued by the State; and (B) motor vehicle drivers' histories, including motor vehicle violations, suspensions, and points on licenses. Capture of Residence and Mailing Addresses Evaluate and provide recommendations to modify DLS application and databases to allow capture of customer residence and mailing addresses. DLS Changes for Duplicates and Corrections Make changes to DLS application for issuance of duplicates (replacement) and corrections to DL and ID cards to include change of name, change of address, change of other information, and duplicate issuance. Capture Digital Images of Documents Employ technology to capture digital images of identity source documents so that the images can be retained in electronic storage in a transferable format. Color Images DHS is proposing that if a State employs digital imaging of source documents, it capture the image in color Link Document Images to Driver Records All images must be linked to the applicant through the applicant’s unique identifier assigned by the DMV. As an alternative, a State may retain the paper copies of the source documents until it develops an electronic system. AAMVA Digital Exchange Program DHS is proposing that if a State employs digital imaging of source documents, it use the AAMVA Digital Image Exchange Program for this purpose

NPRM

TORFP

SY1

§ 37.33

M.o M.o1 M.o2

SY2

M.t

SY3

Sec. II.J

M.r1 M.r2 M.r3 M.r4

SY4

Sec. II.J

M.e M.e1

SY5

Sec. II.J

M.e M.e1

SY6

Sec. II.J

M.e1

SY7

Sec. II.J

M.e1 M.n2

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Project Requirements
Image Formats Photo images should be stored in the Joint Photographic Experts Group (JPEG) 2000 standard for image compression, as modified in the future. Document and signature images should be stored in a compressed Tagged Image Format (TIF). Facial Image Storage Policy If a driver’s license or identification card is not issued, DHS is proposing that States dispose of the facial image photograph after one year. Document Retention Periods Retain paper copies of source documents for a minimum of 7 years or images of source documents presented for a minimum of 10 years. Data Quality and Formatting State shall document business rules for reconciling data quality and formatting issues and work with other states to develop best practices and common business rules by means of a collective governance structure. Other States Access to MVA Data Provide electronic access to all other States to information contained in the motor vehicle database of the State.

NPRM

TORFP

SY8

Sec. II.J

M.e M.e1

SY9

Sec. II.H.3

SY10

Sec. II.G

M.e M.e1 M.f

SY11

Sec. II.C.1.a Sec. II.K.5

M.n M.n1 M.n2 M.e3 M.e4 M.n M.n1 M.n2

SY12

Subpart C, § 37.33

Real ID Requirements Traceability Analysis      

   

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# TE1

Project Requirements
Temporary DL/ID Issuance If a person presents a valid, unexpired nonimmigrant visa or nonimmigrant visa status for entry into the United States; has a pending application for asylum in the United States; has a pending or approved application for temporary protected status in the United States; has approved deferred action status; or has a pending application for adjustment of status to that of an alien lawfully admitted for permanent residence in the United States or conditional permanent resident status in the United States, the State may only issue a temporary driver's license or temporary identification card to the person.

NPRM

TORFP

Sec. II.G

M.i M.m

TE2

Temporary DL/ID Validity Period A temporary driver's license or temporary identification card shall be valid only during the period of time of the applicant's authorized stay in the United States or, if there is no definite end to the period of authorized stay, a period of one year. - A temporary driver's license or temporary identification card shall clearly indicate that it is temporary and shall state the date on which it expires.

Sec. II.G

M.c1 M.c2

TE3

Temporary DL/ID Renewal A temporary driver's license or temporary identification card issued pursuant to this subparagraph may be renewed only upon presentation of valid documentary evidence that the status by which the applicant qualified for the temporary driver's license or temporary identification card has been extended by the Secretary of Homeland Security. M.g Temporary In-Person Renewals Holders of temporary REAL ID driver’s licenses and identification cards must renew their driver’s licenses and identification cards in person at each renewal

Sec. II.G

M.g

TE4

Sec. II.I.2

M.g

Real ID Requirements Traceability Analysis      

   

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Project Requirements
Document Verification State shall verify, with the issuing agency, the issuance, validity, and completeness of each document required to be presented by the person. Verification of Identity Information Procedures If EVVE is either not available nationally by the effective date of the regulations, or a State is seeking to verify the validity of a birth certificate from a State that is not participating in the EVVE system, a State may establish written procedures for how it will attempt to verify such records, and document its use of those procedures. At a minimum, the applicant’s file and/or records should contain a notation that the birth certificate information was not verified electronically with the issuing agency. Electronic Verification of Identity Information If EVVE is not available nationally by the effective date of the regulations, or a State is seeking to verify the validity of a birth certificate from a State that is not participating in the EVVE system, such electronic verification will be necessary at the first driver’s license or identification card renewal or reissuance once the information is available for electronic verification Verification of Lawful Status States shall verify the authenticity of the identity documentation and lawful status in the United States at the same time, using the SAVE system. Verification of Lawful Status For Student Aliens Student aliens admitted for duration of status (D/S), states should use the Student and Exchange Visitor Information System (SEVIS) for verification.

NPRM

TORFP

VE1

Sec. II.E.2.a

M.d7

VE2

Sec. II.E.2.a

M.d7 M.g

VE3

Sec. II.E.2.a

M.d7

VE4

Sec. II.E.3

M.d7 M.g M.l M.m M.d7 M.g M.l M.m

VE5

Sec. II.E.3

Real ID Requirements Traceability Analysis      

   

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# VE6

Project Requirements
SAVE System MOU Not later than September 11, 2005, the State shall enter into a memorandum of understanding with the Secretary of Homeland Security to routinely utilize the automated system known as Systematic Alien Verification for Entitlements, as provided for by section 404 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (110 Stat. 3009664), to verify the legal presence status of a person, other than a United States citizen, applying for a driver's license or identification card.

NPRM

TORFP

Sec. II.E.3

Real ID Requirements Traceability Analysis      

   

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