Know your customer policies are used by business organisations and regulatory bodies to prevent money laundering, fraud, terrorism funding and identity theft etc.

In the FAQ section related to Know Your Customer (KYC) Guidelines, Reserve Bank of India states that KYC is a process by which banks obtain information about the identity and address of the customers. This process helps to ensure that banks’ services are not misused.

Ensuring that all have your latest address is a nightmare

The implementation of the KYC guidelines is of relatively recent origin. However, for someone who during the course of last 36 years of banking career has been posted to 23 stations (yes, twenty-three!), some of them repeat, and changed residence 34 times (yes, thirty-four!) over the same period, ensuring that all organisations that you are customer of have your latest address is a nightmare. Every organisation has its own set of rules and interpretation of those rules at the field level is even more diverse. Further confounding the whole issue are the repeated changes to the rules from time to time.

While complying with the proof of identity is not very difficult since PAN card is universally accepted, complying with the proof of address is a nightmare. Almost all of my documents viz. PAN card, passport, bank passbook, driver license and voter id carry different addresses. The lease of the apartment we are currently living happens to be in the name of my wife and for the same reason the landline connection is also in her name. Thus, I do not have a single document in my own name to provide proof of address.

Cornered, they only express their helplessness and take shelter behind organisation policy.

Ideally, the lease agreement or landline connection in the name of spouse/parent/children should be admissible as adequate proof of address. However, everywhere I have encountered resistance as they invariably ask for proof of address in my own name. I have countered them, generally, by asking them what proof of residence they can produce for themselves. As most of these persons I encountered were youngsters or women, they were invariably living with their parents or spouse and hence were unable to respond. Cornered, they only express their helplessness and take shelter behind organisation policy. Incidentally, my recent research led to SEBI Circular MIRSD/Cir- 26 /2011 dated December 23, 2011 which clearly states that the proof of address in the name of the spouse may be accepted.

I enquired if he would be willing to gift me one of his properties for my permanent residence

Another issue I frequently face is related to my ‘Permanent Address’. For someone who has changed residence thirty-four time in the last 36 years, I do not have any ‘Permanent Residence’. This led to an interesting exchange with a police official a few years back. The said official was responsible for tenant-verification. On examining the form filled by me he pointed out that the rented house itself cannot be the permanent address. I told him that I do not have any other address. The police official would not accept that as an explanation and insisted that being such a senior official I must be owning property somewhere or must be having some ancestral property. I responded by advising him that neither my late father nor I have earned enough to be able to own a house of our own. Disbelieving this, he insisted that I must be earning very well. I bluntly told him that unlike him, I do not make any money other than the salary I earn. I further added that being a policeman he must be making good money and owning several properties, and enquired if he would be willing to gift me one of his properties for my permanent residence. The policeman completed the formalities without any further comment.

This is not the end of my troubles, however. Having recently returned to India for permanent residence, rules require that Banks change the status of my NRO/NRE accounts to resident accounts. Each Bank has a different set of requirements. One is asking for me to furnish a new account opening form whereas another one is quoting system limitations in changing the status to resident. I am still grappling with this.