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 Version no. Description of Change Author

November 8, 2007 0.1 SPS
November 9, 2007 1.0 Submitted to MVA SPS

1 INTRODUCTION

1.1 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 TORFP TRACEABILITY TABLE

2.1 Legend

# TORFP requirement numbering.

Sec.II, B
NPRM requirements are presented by the reference to the paragraphs in the NPRM document.
(example)
CA1
Project Requirements are presented by their numbers
(example)

2.2 TORFP Traceability Table.

Requirements

# NPRM Project Reject

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 Sec. II.H.1
a application development. The current AAMVA standard CA1
6 CFR Part 37
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 Sec. II.H.1
a1 field. CA1
6 CFR Part 37

Evaluate and provide recommendations for maintaining a

single demographic database for all business applications.
a2

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 Requirements

# NPRM Project Reject

Evaluate and provide recommendations for application of the

same identity standards (Real ID Act Std.) to all business
a3
applications.

Evaluate and provide recommendations to determine

legislative changes required.
a4

Evaluate and provide recommendations for segregating

demographic databases for DLS and all other business
a5 systems.

Evaluate and provide recommendations for discrepancy,

precedence, synchronization and other issues between
a6 databases.

b Integrate the following new or modified features into the CA1, CA2,
DL and ID cards:
Sec. II.H.1 CA3,CA4,
6 CFR Part 37 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
CA1
6 CFR Part 37

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 6 CFR Part 37 §
changes are required to place residence address on CDL CA6
37.17 . (f)
card.

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 Requirements

# NPRM Project Reject

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.
§ 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 § 37.19 CA9
encryption.

b5 New card requirements for compliance with DHS standards. CA1, CA2,
Sec. II.H.1
CA3,CA4,
6 CFR Part 37,
CA6,CA6,
§ 37.17 . (f)
CA7, CA8
Develop temporary DL/ID cards with expiration of card
coinciding with the end of permitted stay or issuance for
c no more than 1 year.

Evaluate and provide recommendations to modify DLS

application to allow user definable expiration date on
c1 temporary cards. MD legislation will be required in order to Sec. II. G TE2
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
c2 “different than usual” expiration date. Sec. II. G TE2

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 Requirements

# NPRM Project Reject

d Establish electronic interfaces to identity document and

status issuance sources for verification of customer
identity documents and integrate into DLS application.

d1 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.
d2 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)

d4 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.

d5 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.

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 Requirements

# NPRM Project Reject

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.

d7 General Manual Verification – Evaluate and provide

recommendations for manual verification options and
processes where electronic interfaces are not available or
VE1, VE2,
Sec. II. E.2.a, F
feasible. VE3, EX2, EX3

Capture digital images of identity source documents so

that images can be retained in electronic storage in a
transferable format.
Sec. II.H.1 SY4, SY5,
e
6 CFR Part 37 SY8, SY10

Evaluate and provide recommendations to modify DLS

application to require capture of additional scanned SY4, SY5,
documents.
Sec. II.H.1
e1 SY6,SY7, SY8,
6 CFR Part 37
SY10

Evaluate and provide recommendations to develop DLS

interface to Foster Freeman Document Comparator for image
e2 capture.

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 Requirements

# NPRM Project Reject

Evaluate and provide recommendations to create application

to transmit document images to other agencies and
jurisdictions.
Sec. II.H.1
e3 SY12,
6 CFR Part 37

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
e4 SY12,
6 CFR Part 37

f Retain images of source documents presented for a

minimum of 10 years.
Sec. II.H.1
SY10
6 CFR Part 37

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 CE1
Sec. II.K.5
Sec. III.
Establish an effective procedure to confirm or verify a CE1, EX1,
renewing applicant’s information. Sec. II.K.1
Sec. II.K.5 RE1, RE2,
g
Sec. III. Sec. RE3, RE4,
II.I.2, 4 TE3, TE4, VE2
Evaluate and provide recommendations to modify DLS to
include indicators signifying that certain data and / or
g1 documents have been verified and validated. Sec. II.K.1 CE1
Sec. II.K.5
Sec. III.
Evaluate and provide recommendations to create required
audit trail indicators for verified and validated data.
g2 Sec. II.K.1 CE1
Sec. II.K.5
Sec. III.

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 Requirements

# NPRM Project Reject

h Ensure physical security of locations where DL/ID cards

are produced.
Sec. II.K.1 SE1

h1 Evaluate and provide recommendations to determine and

document required procedures and physical / electronic
security measures for distributed card productions at MVA Sec. II.K.1 SE1, SE5
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.
SE3, SE4,
i Sec. II.K.1
SE5, SE6

Evaluate and provide recommendations to determine and

document security clearance requirements for persons
i1 authorized to manufacture or produce cards at MVA branch Sec. II.K.1 SE3, SE4, SE6
offices, MVA centralized production and outsourced
centralized production.
Evaluate and provide recommendations to develop legislation
authorizing MVA to conduct certain types of security checks.
i2 Sec. II.K.1 SE3, SE6

j Establish fraudulent document recognition training

programs for appropriate employees engaged in the
issuance of DL/ID cards. 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

# NPRM Project Reject

j2 Evaluate and provide recommendations to determine

requirements, develop and deliver curriculum for fraudulent
document recognition training. Sec. II.K.1 SE2

Limit period of validity of DL/ID cards that are issued to

military license holders who are stationed outside of
k 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 Sec. II.G, H.3 PR5, RE2

Evaluate and provide recommendations to develop legislation

required limiting the validity period.
k2 Sec. II.G, H.3 PR5, RE2

l Determine business rules, processes, DLS modifications

and card designs (DL / ID / Driving Certificate) required
assuming that Maryland will NOT REQUIRE Legal
II.D.1, Sec.
DO3, TE1
Presence for the issuance of DL / ID cards. II.G

l1 Evaluate and provide recommendations to develop legislation

for this requirement.

Determine business rules, processes, DLS modifications

and card designs (DL / ID) required assuming that
Maryland WILL REQUIRE Legal Presence for the
II.D.1, Sec.
m DO3, TE1
issuance of DL / ID cards. II.G

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 Requirements

# NPRM Project Reject

Evaluate and provide recommendations to develop legislation

for this requirement.
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
SY11, SY12
Sec. II.K.5

n1 Evaluate and provide recommendations to determine

requirements for allowing access to MVA databases by other
agencies and jurisdictions.
Sec. II.C.1.a
SY11, SY12
Sec. II.K.5

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 SY7, SY11,
Sec. II.K.5 SY12

Maintain a database that contains at a minimum:

o Sec. II.J SY1

Evaluate and provide recommendations to include all data

fields printed on DL/ID cards.
o1 Sec. II.J SY1

Evaluate and provide recommendations to include driver

histories, including motor vehicle violations, suspensions and
o2 points on licenses. Sec. II.J SY1

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 Requirements

# NPRM Project Reject

Evaluate and provide recommendations for modifications to

the DLS application and the DLS databases.
o3

p Evaluate and provide recommendations for utilization of

3rd party providers for:

p1 Validation and verification of identifying documents.

p2 Performing all DL and ID services currently performed in an

MVA branch office.

p3 Performing background / security clearance checks on

current and new DL and ID personnel (contractor and MVA
employed).

Develop and document business processes and

procedures for issuance of duplicates (replacements)
and corrections to DL and ID cards to include: 1) Change
q of address, 2) Change of name, 3) Change of other Sec II, H.6 PR3
information, 4) Duplicate (replacement) issuance

Develop and document business processes and procedures

for issuance of duplicates (replacements) and corrections to
q1 DL and ID cards to include Change of address Sec II, H.6 PR3

Develop and document business processes and procedures

for issuance of duplicates (replacements) and corrections to
q2 DL and ID cards to include Change of name Sec II, H.6 PR3

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 Requirements

# NPRM Project Reject

Develop and document business processes and procedures

for issuance of duplicates (replacements) and corrections to
q3 DL and ID cards to include Change of other information Sec II, H.6 PR3

Develop and document business processes and procedures

for issuance of duplicates (replacements) and corrections to
q4 DL and ID cards to include Duplicate (replacement) issuance Sec II, H.6 PR3

r 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) Sec.II, B SY3
Change of other information, 4) Duplicate (replacement)
issuance

r1 DLS application changes for issuance of duplicates

(replacement) and corrections to DL and ID cards to include
Change of address 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

# NPRM Project Reject

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)
s PR2
Development of legislative changes needed to allow 3rd
party provider law and skills testing.

Utilization of 3rd party providers for Central issuance of DL

and ID cards
s1 PR2

Utilization of 3rd party providers for Non-Commercial Driver

License Law Testing
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
s4 and skills testing.

t Evaluate and provide recommendations to modify DLS

application and databases to allow capture of customer
residence and mailing addresses. CA6, SY2

Evaluate and provide recommendations to replace

Soundex Number with a unique, permanent Customer
u Account Number in DLS and all other business
applications.

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 Requirements

# NPRM Project Reject

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

v1 Biometric Customer Identification for Facial Recognition

Subpart D,§
PR8
37.41

v2 Biometric Customer Identification for Finger Scan

Subpart D,§
PR8
37.41

v3 Biometric Customer Identification for Iris Scan

v4 Legislative changes to allow biometric identification

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
w 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

# NPRM Project Reject

Waiver of vision certification for all DL renewals that are

currently restricted with corrective lenses
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 RE5

Legislative changes to allow renewal of ID cards.

x2

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)
y 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

# NPRM Project Reject

processing.

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
y2 order

Modules for the MVA e-commerce (eMVA) and mail-in

applications to allow Business and Salesman license
y3 renewals, corrections and duplicates (replacements)

Modules for the MVA e-commerce (eMVA) and mail-in

applications to allow eMVA to interface with the point of sale
y4 (POS) system for all payment processing.

z 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.
z1 Redistributing driver license renewals evenly over the 5-year
cycle

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 Requirements

# NPRM Project Reject

z2 Legislative changes needed to allow renewal periods that are

less than or greater than 5 years.

Evaluate and provide recommendations for:

1) Eliminating the Employer Name step in the DLS
aa 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.

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3 PROJECT REQUIREMENTS

3.1 Legend

Originated Outside NPRM and TORFP

CA10

CE7 Exclusively NPRM ORIGINATED

SY9 Exclusively TORFP ORIGINATED

Sec.II, B NPRM requirements are presented by the reference to the paragraphs in the NPRM
(example) document.
M.a1 TORFP

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3.2 Project Requirements Traceability Table
# Project Requirements NPRM TORFP
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 M.a
license or identification card, DHS is proposing to adopt the Sec. II.H.1 M.a1
CA1 ICAO 9303 Standard...the standard requires Roman alphabet 6 CFR Part 37 M.b1
characters, allows a total of 39 characters on the face of the M.b5
driver’s license or identification card, and provides standards
for truncation of longer names.

Date Of Birth
State shall include, at a minimum, the following information
and features on each driver's license and identification card Sec. II.H.2
CA2 M.b5
issued to a person by the State: The person's date of birth. 6 CFR Part 37

Gender
State shall include, at a minimum, the following information Sec 202 c (1) (a)
CA3 and features on each driver's license and identification card Sec. II.H.3 M.b5
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 Sec 202 (b) (3),
CA4 issued to a person by the State: The person's driver's license M.b5
Sec II, H.1
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 Sec 202 (b) (4),
CA5 M.b5
person. Sec II, H.5
- DHS is proposing that digital photographs comply with
current ICAO 9303 standards.

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 # Project Requirements NPRM TORFP
Address Of Principle Residence
State shall include, at a minimum, the following information
and features on each driver's license and identification card M.b2
issued to a person by the State: The person's address of Sec 202c (1)
CA6 M.b5
principle residence. (D), Sec II, H.6
M.t

Signature
State shall include, at a minimum, the following information
CA7 and features on each driver's license and identification card Sec II, H.7 M.b5
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
CA8 issued to a person by the State: Physical security features Sec II, H.8 M.b3
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
Sec. II.H.8 M.b3
CA9 described in the 2005 AAMVA Driver’s License/Identification
Card Design Specifications, Annex D, as its MRT data 6 CFR Part 37 M.b4 M.b5
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
CA10 driver’s license and identification card is compliant.

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 # Project Requirements NPRM TORFP
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
CA11 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. Sec. II.K.1
M.f1
-States shall document procedures for resolving data Sec. II.K.5
CE1 formatting, quality, and integrity issues. DHS encourages M.g1
Sec. III. State
States to draft collective standards and best practices for the M.g2
Certification
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.

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, Sec. II.B.(1)
CE2 2008 compliance date required under the Act. DHS strongly
encourages States to communicate their intent to certify
Sec. II.B.(3)
compliance or request an extension by October 1, 2007.

Real ID Requirements Traceability Analysis      
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 # Project Requirements NPRM TORFP
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 Sec. II.B.(1)
CE3 encourages States to communicate their intent to certify Sec. II.B.(3)
compliance or request an extension by October 1, 2007.

Extension Request
The State shall request an extension of the certification Sec. II.B.(2)
CE4 deadline based on the lack of a final REAL ID rule by filing Sec. II.B.(3)
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, M.h
CE5 databases, and systems utilized for collecting, disseminating Sec. II.C.1.a
M.h1
or storing information used in the issuance of REAL ID
licenses.
Annual Certification
States shall resubmit plans on an annual basis until all
CE6 requirements of the rules are met. Sec. II.B.(3)

Quarterly Reports
Paperwork Reduction Act -- States will also submit quarterly
CE7 reports analyzing their use of the exceptions process and Sec. VII.A
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 Sec. II.D.2.a
legal name and date of birth. Sec. II.D.2.b
DO1 M.d7
- Documentation showing the person's date of birth. Sec. II.D.2.c
- Documentation showing the person's name and address of Sec. II.E.5
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.

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 # Project Requirements NPRM TORFP
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.
DO2 II.D.1
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

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 M.l
DO3 entered into the United States in refugee status; (v) has a
II.D.1
M.m
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.

Real ID Requirements Traceability Analysis      
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 # Project Requirements NPRM TORFP
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
EX1 Sec. II.F M.g
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
EX2 with another person to which any State has issued a driver's Sec. II. E.2.a, F M.d7
license or identification card, the State shall resolve the
discrepancy and take appropriate action.

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 Sec. II.E.2.a
EX3 cases should not preclude persons from obtaining a REAL ID M.d7
Sec. II.F
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
EX4 each State should continue to address these situations Sec. II.H.4
through a written and documented exceptions process.

Real ID Requirements Traceability Analysis      
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 # Project Requirements NPRM TORFP
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
PR1 cards issued under the new rules in order to be accepted by II.B.(3)
Federal agencies for official purposes after May 10, 2013.

Central Issuance
Utilize 3rd party providers for Central issuance of DL and ID M.s
PR2 cards M.s1

Duplicates and Corrections

Develop and document business processes and procedures M.q
for issuance of duplicates (replacements) and corrections to M.q1
PR3 DL and ID cards to include Change of name, change of Sec II, H.6 M.q2
address, change of other information, and duplicate issuance
M.q3
M.q4

Out of State
Refuse to issue a driver's license or identification card to a
PR4 person holding a driver's license issued by another State 6 CFR Part 37 M d7
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 M.k
PR5 identification cards that are not temporary to a period that Sec. II.G M.k1
does not exceed 8 years.
M.k2

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
PR6 years and reflect that a driver’s license or identification card Sec. II.H.3
was not issued for that purpose

Facial Image Capture

Subject each person applying for a driver's license or Subpart B, §
PR7 identification card to mandatory facial image capture 37.11

Real ID Requirements Traceability Analysis      
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 # Project Requirements NPRM TORFP
Biometrics
Evaluate and provide recommendations to develop Biometric
Customer Identification for: 1) Facial Recognition, 2) Finger Subpart D,§ M.v1
PR8 Scan. 37.41 M.v2

Verify Renewal Information

Establish an effective procedure to confirm or verify a M.d7
RE1 renewing applicant's information. Sec. II.I.2
M.g

In-Person Renewal Period

M.g
RE2 Sec. II.I.2 M.k1
M.k2
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 M.g
RE3 Sec. II.I.2
individual need not resubmit documents for verification as long M.d7
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
RE4 driver’s license or identification card, to assure there is no Sec. II.I.1 M.g
match against death information recorded with either the State
vital statistics offices or SSA.

ID Card Renewals
Institute renewals for ID cards M.x
RE5 Sec. II.I.2
M.x2
Physical Security
Ensure the physical security of locations where drivers'
licenses and identification cards are produced and the security M.h
SE1 of document materials and papers from which drivers' licenses Sec. II.K
M.h1
and identification cards are produced.

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 # Project Requirements NPRM TORFP
Fraudulent Document Recognition Training
Establish fraudulent document recognition training programs M.j
for appropriate employees engaged in the issuance of drivers' Subpart D, §
SE2 M.j1
licenses and identification cards. 37.41
M.j2

Background Checks for Covered Personnel

Subject all persons authorized to manufacture or produce M.i
drivers' licenses and identification cards to appropriate
SE3 security clearance requirements.
Sec. II.K.1 M.i1
M.i2

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 M.i
SE4 Sec. II.K.1
those individuals through the Federal Bureau of Investigation M.i1
(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 M.h1
SE5 Sec. II.K.1
waiver processes and provide them to DHS as part of the M.i
State’s comprehensive security plan.

Financial History Checks

DHS is proposing that the States perform a financial history M.i
SE6 check on individuals seeking employment in covered Sec. II.K.1 M.i1
positions. M.i2

Outsourcing Background Checks

Evaluate and provide recommendations for utilization of 3rd
party providers for performing background / security clearance
SE7 checks on current and new DL and ID personnel (contractor M.p3
and MVA employed).

Real ID Requirements Traceability Analysis      
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 # Project Requirements NPRM TORFP
Motor Vehicle Database
Maintain a State motor vehicle database that contains, at a
minimum -- (A) all data fields printed on drivers' licenses and M.o
SY1 identification cards issued by the State; and (B) motor vehicle § 37.33 M.o1
drivers' histories, including motor vehicle violations,
M.o2
suspensions, and points on licenses.

Capture of Residence and Mailing Addresses

Evaluate and provide recommendations to modify DLS
SY2 application and databases to allow capture of customer M.t
residence and mailing addresses.

DLS Changes for Duplicates and Corrections

Make changes to DLS application for issuance of duplicates M.r1
(replacement) and corrections to DL and ID cards to include M.r2
SY3 change of name, change of address, change of other Sec. II.J
M.r3
information, and duplicate issuance.
M.r4

Capture Digital Images of Documents

Employ technology to capture digital images of identity source
documents so that the images can be retained in electronic M.e
SY4 Sec. II.J
storage in a transferable format. M.e1

SY5 Color Images

DHS is proposing that if a State employs digital imaging of M.e
source documents, it capture the image in color Sec. II.J
M.e1

SY6 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 Sec. II.J M.e1
documents until it develops an electronic system.

SY7 AAMVA Digital Exchange Program

DHS is proposing that if a State employs digital imaging of
source documents, it use the AAMVA Digital Image Exchange M.e1
Sec. II.J
Program for this purpose M.n2

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 # Project Requirements NPRM TORFP
Image Formats
Photo images should be stored in the Joint Photographic
Experts Group (JPEG) 2000 standard for image compression, M.e
SY8 as modified in the future. Document and signature images Sec. II.J
M.e1
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
SY9 proposing that States dispose of the facial image photograph Sec. II.H.3
after one year.

Document Retention Periods

Retain paper copies of source documents for a minimum of 7 M.e
SY10 years or images of source documents presented for a Sec. II.G M.e1
minimum of 10 years. M.f

Data Quality and Formatting

State shall document business rules for reconciling data
quality and formatting issues and work with other states to M.n
Sec. II.C.1.a
SY11 develop best practices and common business rules by means M.n1
Sec. II.K.5
of a collective governance structure. M.n2

SY12 Other States Access to MVA Data

M.e3
Provide electronic access to all other States to information
contained in the motor vehicle database of the State. M.e4
Subpart C, §
M.n
37.33
M.n1
M.n2

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 # Project Requirements NPRM TORFP
TE1 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 M.i
that of an alien lawfully admitted for permanent residence in Sec. II.G
M.m
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.

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. M.c1
- A temporary driver's license or temporary identification card
Sec. II.G
M.c2
shall clearly indicate that it is temporary and shall state the
date on which it expires.

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
TE3 status by which the applicant qualified for the temporary Sec. II.G M.g
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
TE4 identification cards must renew their driver’s licenses and Sec. II.I.2 M.g
identification cards in person at each renewal

Real ID Requirements Traceability Analysis      
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 # Project Requirements NPRM TORFP
Document Verification
State shall verify, with the issuing agency, the issuance,
VE1 validity, and completeness of each document required to be Sec. II.E.2.a M.d7
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
M.d7
VE2 Sec. II.E.2.a
use of those procedures. At a minimum, the applicant’s file M.g
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
VE3 system, such electronic verification will be necessary at the Sec. II.E.2.a M.d7
first driver’s license or identification card renewal or
reissuance once the information is available for electronic
verification

VE4 Verification of Lawful Status

States shall verify the authenticity of the identity M.d7
documentation and lawful status in the United States at the M.g
Sec. II.E.3
same time, using the SAVE system. M.l
M.m
VE5 Verification of Lawful Status For Student Aliens
Student aliens admitted for duration of status (D/S), states M.d7
should use the Student and Exchange Visitor Information M.g
Sec. II.E.3
System (SEVIS) for verification. M.l
M.m

Real ID Requirements Traceability Analysis      
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 # Project Requirements NPRM TORFP
VE6 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 Sec. II.E.3
and Immigrant Responsibility Act of 1996 (110 Stat. 3009-
664), to verify the legal presence status of a person, other
than a United States citizen, applying for a driver's license or
identification card.

Real ID Requirements Traceability Analysis      
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