RM 10212: Legal Names and Changes to the Numident
TN 1 (02-10)
Some name change requests may be based on acceptable name change documents that are not acceptable evidence of identity because they are too old or do not show sufficient biographical information. In these situations evidence of identity is required in addition to the name change document. Generally, we ask for evidence of identity in the prior name, to link the NH and new name to the Numident. However, we can accept evidence of identity in the new name under certain conditions. This section explains under what conditions evidence of identity in the new name is acceptable when the name change document alone is not sufficient to process a name change.
A. Evidence of name change event and new name
Always require acceptable evidence of
the name change event, and
new name (name to be shown on SSN card).
B. Evidence of identity in the new name
Evidence of identity in the new name (to be shown on the SSN card) which meets the requirements of RM 10210.405 can be used to process the name change when:
the name change document (e.g., marriage document) shows the prior name that agrees with the latest Numident record (e.g., maiden name). When the prior name shown on the name change document does not agree with the name on the latest Numident record, request prior name change documents to establish a link between the name shown on the name change document and the latest Numident record; and
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the following identifying information from the latest Numident record propagated into the Enumeration system matches the information provided by the applicant and shown on the documents submitted:
SSN,
name(s) on latest Numident record,
date of birth,
place of birth,
parents’ names
NOTE: Consider the identifying information to match if there are minor spelling errors, mother’s maiden name is incorrect or unknown, or place of birth provided is County of birth instead of city.
C. Example of name change based on marriage with evidence of identity in the new name
Sue Johnson has been married for over 30 years. Recently, she learned she never changed her last name on her Social Security card to her husband’s last name (the name she has been using since marriage) when the DMV was unsuccessful at electronically verifying her name and SSN. In addition, Ms. Johnson recently applied for spouse’s benefits, and SSA confirmed her name had never been changed on her SSN card.
The name on the latest Numident record is Sue Davis. Mrs. Johnson alleges not having any evidence of identity in the prior name. All of her identity documents are now in her married name, including her driver’s license. She submits evidence of the name change event, her marriage document. The new name (Johnson) can be derived from the marriage document. Since the marriage took place over two years ago, Ms. Johnson must submit evidence of identity in addition to her marriage document.
In this situation, apply the evidence of identity in new name criteria to determine if the name change can be processed:
The marriage document shows Sue Davis married Al Johnson.
Her driver’s license is in the new name, Sue Johnson; and
All of the identifying information (SSN, names on prior records, date of birth, place of birth, parents’ names), based on her allegation and the driver license and marriage document, matches the latest Numident record
We can process the name change.
D. Example of name change based on divorce with evidence of identity in the new name
Laura Brooks wants to receive an SSN card in the name Brooks. She submits evidence of a name change event, her divorce decree. She changed her last name on the Social Security card from her maiden name (Brooks) to her husband’s last name (Thompson) soon after marriage but never changed her name back to her maiden name (Brooks) after the divorce. The divorce decree does not specify the new name or provide any identifying information. Her Numident record shows a prior card was issued in the name Laura Brooks, which can be used to establish the new name. Since the divorce does not meet the criteria for evidence of identity for the number holder, evidence of identity in addition to the name change document is required to process the name change.
Ms. Brooks never used her husband’s last name and alleges not having identity documents in the name on the latest Numident record (her married name of Thompson). She never changed her name to her married name on her driver’s license and is now having problems renewing her license because the DMV cannot verify her name and SSN in “Brooks” because the SSN record is still showing her married last name, Thompson.
In this situation, apply the evidence of identity in new name criteria to determine if the name change can be processed:
The divorce decree indicates the marriage between Laura Thompson and Brad Thompson has been dissolved. The divorce decree shows the prior name as shown on the latest Numident record;
The driver’s license is in the new name, Laura Brooks; and
All of Laura’s identifying information on the latest Numident record (SSN, names on prior records, date of birth, place of birth, parents’ names) matches her allegation and data shown on the divorce decree and driver license.
We can process the name change.
E. Example of name change when the prior name on the marriage document doesn’t match the Numident record
Amy George married Jim Ford in 2007 and wants to change her surname on her Social Security card to Ford. Prior to Amy’s marriage to Jim, she previously married and divorced Ben Smith and then married and divorced Joe George. The name on Amy’s latest Numident record (Amy Smith) does not match the prior name on her marriage document (Amy George) because Amy only updated her information in our records to reflect her name change to Smith because of her marriage to Ben. She didn’t update her information in our records to reflect her divorce from Ben or her marriage to Joe or her subsequent divorce from Joe. As a result, her prior name shown on her current marriage document does not agree with the name shown on the latest Numident record.
To link the name on the name change document (Amy George) to the name on the latest Numident record (Amy Smith), Amy submits her prior divorce decrees to show that her marriage to Ben Smith and her marriage to Joe George have been dissolved. These prior name change documents were also required to establish a link between the surname on the latest Numident record (Smith) and the prior surname shown on the name change documents (George).
In addition to her current marriage document, Amy also submits an identity document (her current driver’s license) in her new name because the name change documents do not meet the criteria to also serve as acceptable evidence of identity for the number holder (marriage occurred over 2 years ago).
In this situation apply the evidence of identity in new name criteria to determine if the name change can be processed.
Her new name can be derived from the marriage document. While the prior name shown on the current marriage document does not agree with the latest Numident record, the prior divorce decrees link the name shown on the current marriage document and the latest Numident record,
her divorce decrees show that both her prior marriages have been dissolved,
her driver’s license is in the new name Amy Ford, and
All of Amy’s identifying information on the latest Numident record (SSN, names on prior records, date of birth, place of birth, parents names) matches her allegation and the data shown on the marriage certificate, divorce decrees and her driver’s license.
We can process the name change.
NOTE: When processing the request in SSNAP use the Other Names Used field and the Remarks field to document the prior names and evidence submitted to link all the names.
F. Reference
RM 10212.055, Evidence Required to Process a Name Change based on Marriage, Civil Union, or Domestic Partnership
RM 10212.065, Evidence Required to Process a Name Change based on Divorce, Dissolution or Annulment on the SSN
RM 10212.070, Evidence Required to Process a Name Change based on Naturalization
RM 10212.085, Evidence Required to Process a Name Change based on a US Court Order Name Change
RM 10212.095, Evidence Required to Process a Name Change based on a US Issued Amended or Corrected Birth Certificate