POMS Reference

RM 10212: Legal Names and Changes to the Numident

TN 1 (02-10)

The following are commonly requested name corrections.

NOTE: Resolve other issues or discrepancies on the Numident according to SSN policy.

See also:

RM 10215.200, General Information About Special Indicators

RM 10225.080, Policy on Social Security Number (SSN) Application on Behalf of Deceased Persons

Name Correction

Reference

Last Numident record created by SSA

RM 10212.160A

Child’s name recorded incorrectly by State vital records office

RM 10212.160B

Last Numident record shows part of compound name

RM 10212.160C

Name on Numident record is a nickname

RM 10212.160D

Middle name is shown as first name on Numident record

RM 10212.160E

NL2 line shows the legal name

RM 10212.160F

Name on Numident is different from name on immigration document

RM 10212.160G

Name based on current marriage, civil union and domestic partnership

RM 10212.160H

A. Last Numident record created by SSA

Mary Jones contacts SSA because the Department of Motor Vehicles (DMV) says that SSA does not verify the name and SSN information she provided to them when applying for a driver’s license. She submits to SSA evidence of identity in her name (Mary Jones). Although the last Numident record shows her name as Mary Logsdon, at least one Numident record shows her name as Mary Jones. The microprint of the SSA document for that Numident record was not an SS-5, but an OCRO-completed CO-7003.2 prepared in 1977 by SSA to change her name on the Numident. Mary says she always used the name Mary Jones and never used the name Mary Logsdon.

If all efforts fail to produce either any evidence in the name “Mary Logsdon” or that the NH ever used the name on the last Numident record, follow RM 10212.160 to curtail development. This situation is a name correction if the applicant is determined to be the number holder and did not complete the SS-5 for the name shown on the last Numident record.

NOTE: This is the ONLY instance when you can follow this procedure. If there is an SS-5 signed by the number holder, or an attested electronic record, one of the other name correction situations must apply or legal name change event must have occurred per RM 10212.001.

B. Child’s name recorded incorrectly by State vital records office

Anne Stallcop’s name was recorded incorrectly as “Anne Stalcup” by the State office of vital records. She was subsequently issued an SSN card through EAB (Enumeration at Birth) also showing her name incorrectly as “Anne Stalcup.” The State subsequently corrected the birth record and issued her a new birth certificate (BC). Because the State made the error, Anne does not have any identity document in the incorrect name (the name on the Numident record of “Anne Stalcup”).

Accept:

  1. evidence of identity in the correct name of Anne Stallcop,

  2. the birth record in the correct name, and

  3. either:

    • through information received from the State office of vital records showing that when it originally recorded the birth record for Anne that it recorded her last name incorrectly as “Stalcup” rather than “Stallcop”, or that the basis for the amended birth record is to correct the error made by the State; or

    • a statement from the hospital stating that the staff there completed the birth registration information in error when submitting it to the State.

Ask for evidence of identity for Anne in the correct name.

This situation is not considered a legal name change, since the state or hospital provided incorrect name data to SSA. However, in some situations, it will be more practical to document the correction following the legal name change procedures for an amended/corrected BC, in RM 10212.095.

NOTE: Generally, when the State records a child’s name incorrectly and the Enumeration at Birth (EAB) record sent to SSA shows the name incorrectly because of that State’s recordation error, the State may inform SSA of the name error. Also, in some States, the State office of vital records will inform parents that the child’s name was recorded incorrectly and issue the child a BC showing the name correctly.

C. Last Numident record shows part of compound name

Antonio applies for a replacement SSN card. He:

  • Completes an SS-5 showing his last name as “Cruz Perez;”

  • signs the SS-5 as “Antonio Cruz Perez;”

  • submits his BC showing his name as Antonio (first name) Cruz Perez (last name); and

  • submits an identity document (U.S. driver’s license (DL)) showing his name as “Antonio (first name) Cruz Perez (last name).”

The last Numident record shows his name as Antonio (first name) Cruz (middle name) Perez (last name). The Numident shows the NH’s name incorrectly because:

  • Antonio incorrectly completed the prior SS-5 by showing part of his compound last name as a middle name and part of the compound last name as a last name and when SSA reviewed the SS-5, it did not correct that error, OR

  • When Antonio applied for the SSN card, the SSA employee incorrectly entered part of his compound surname into the Enumeration system as a middle name.

The name to be shown on the card agrees with the name on the identity document in the name on the BC. He does not have any document showing his last name the way it is shown on the last Numident record (middle name of Cruz and last name of Perez). If all biographical information shown on the Numident agrees with information shown on the evidence of the legal name (BC) and evidence of identity (DL) per RM 10212.150C, the name correction can be processed to show the compound last name.

D. Name on Numident Record Is a Nickname

Robert Moser contacts SSA because the DMV says that SSA does not verify the name and SSN information he provided to them. He submits to SSA evidence of identity and his BC in his name (Robert Moser). However, the Numident record shows his name as Bob Moser. The CYD indicates the SS-5 was processed in 1980 when Mr. Moser was a teenager (age 15) and before SSA’ legal name policy was in effect. Mr. Moser alleges that “Bob” is a nickname for Robert, which he used at the time. All biographical information on the documents, other than the first name, agrees with the Numident. NOTE: In general, this situation will exist only with prior Numident iterations established before 12/17/05, when SSA’s legal name policy became effective.

In this case, evidence of the legal name and evidence of identity following RM 10212.150 C has been submitted. Since Mr. Moser alleges that the first name shown on the Numident is a nickname (whether recognizable to the interviewer or not) and the evidence established the legal name and identity of the number holder, a name correction can be processed.

NOTE: If there is any doubt concerning whether the SSN belongs to the current applicant or whether the name on the Numident is a legal name or nickname, request additional evidence of identity or request the SSA microprint, to confirm the identity of the number holder and whether any evidence submitted with the prior SS-5 would have established the applicant’s legal name (e.g., a BC was submitted). For instructions on requesting a copy of a completed SSN application, see RM 10220.365.

E. Middle name is shown as first name on Numident record

James Zittle contacts SSA because the DMV advises that SSA does not verify the name and SSN information he provided to them. Although his legal name is “James (first name), Andrew (middle name) Zittle (last name),” and that is the name on his birth certificate, driver’s license, and other legal documents, he is known by friends and at work as “Andrew (first name) Zittle (last name)” and the SSA record shows his name as “Andrew (first name) Zittle (last name).” He submits to SSA his birth certificate and expiring driver’s license showing his legal name, James (first) Andrew (middle) Zittle (last). He also submits an employee identification badge showing his name as “Andrew Zittle.” The Numident shows Mr. Zittle completed the prior SS5 before 12/17/05 when SSA’s legal name policy was established. The microprint shows Mr. Zittle completed the SS-5 in 1970 when he was a teenager (age 16) and wrote his name as “Andrew Zittle" . Since he has submitted evidence of this legal name and identity following RM 10212.150C, the name correction can be processed.

NOTE: In this case, the employer ID showing the name on the Numident helps to establish the identity of the applicant as the number holder, but such evidence is not required when the legal name and identity are established per RM 10212.150C. When there is reason to doubt the identity of the NH, request additional evidence of identity or request the SSA microprint, to confirm the identity of the number holder and whether any evidence submitted with the prior SS application would have established the applicant's legal name (e.g. a BC was submitted). For instructions on requesting a copy of a completed SSN application, see RM 10220.365. For processing a legal name change, see RM 10210.210.

F. NL2 line shows the legal name

Patricia Walker contacts SSA because her new employer is unable to verify her name through the SSN verification system. The last Numident shows her name as Patricia (first name) Edwards (last name). The NL2 line on the prior Numident shows her birth name as Patricia (first name) Walker (last name). Patricia explains that, at the time she applied for the last SSN card, she was using her stepfather’s last name, but she alleges she has never been adopted or otherwise legally changed her name. Patricia submits her driver's license showing her name as Patricia (first name) Walker (last name). She does not have her birth certificate with her at the time of the interview and states it is not available. All of the biographical information on Patricia's driver's license and given by her during the interview agrees with what is shown on the Numident.

In this case, since the alleged legal name agrees with the name on the NL2 line, there is no need to request evidence of the legal name such as the birth certificate. Instead, the interviewer requests the SSA microprint for the Numident showing her name as Patricia Edwards. In this case, the microprint shows that Patricia completed the SS-5 before SSA's legal name policy became effective, and only submitted a life insurance policy and medical record as evidence of identity. Since the SSA microprint does not indicate evidence of a legal name change was submitted, and the legal name and identity have been established following RM 10212.150, the name correction can be processed to issue a corrected SSN card. Patricia's new employer will be able to verify her SSN as soon as the new card is received.

NOTE: If the SSA microprint for the prior record did indicate evidence of a legal name change (e.g. a marriage record or adoption decree) had been submitted, Patricia's application should be deleted and an L676 should be issued stating she did not submit sufficient evidence for the name change. Evidence of a legal name change following RM 10212.015 would need to be submitted if a new application is filed.

G. Name on Numident different from name on immigration document

Alejandro Gomez applies for a replacement SSN card to show his legal name Alejandro Gomez. The last Numident record shows his name as, Alex Gomez. He submits to SSA his Form I-551 (Lawful Permanent Resident Card) showing his legal name Alejandro Gomez. Alejandro explains that he changed his name to Alex to Americanize his first name.

The current immigration document is evidence of the legal name per RM 10212.001 and evidence of identity. If all biographical information on the immigration document and supplied by Mr Gomez agrees with the Numident (including an NL2 line, if present), legal name and identity are established following RM 10212.150C and the name correction can be processed.

NOTE: If the most recent Numident was established after 12/17/05, when SSA's legal name policy became effective, or the immigration document was issued before the most recent Numident was established, request the SSA microprint to determine if a legal name change is indicated. If the microprint does indicate evidence of a name change (e.g. a marriage record or court order) was submitted, delete the current application and issue a denial letter stating sufficient evidence for the name change was not submitted. Evidence of a legal name change following RM 10212.015 would be needed if a new application were filed.

NOTE: Since the immigration document was issued before the most recent Numident, the microprint was requested. The microprint shows that Alejandro Gomez did not submit evidence of a legal name change when he applied for the name change in 2004. He never used the name Alex and he does not have any identity documents showing that name. In this case, since “Alex” is not the legal name, this is not a name change but a name correction to show the legal name, Alejandro Gomez.

H. Name based on current marriage, civil union and domestic partnership

Ruth Gonzalez changed her last name on her SSN card to her husband’s surname, Scott, when they married years ago but has never used that name. She is requesting a change in SSA records back to her maiden name, Gonzalez. Her marriage document shows Ruth Gonzalez married Lou Scott. The new name requested (in this case the maiden name, Ruth Gonzalez), can be derived from the marriage document. In addition, Ruth submits her driver’s license in the new name (Ruth Gonzalez). Ruth's legal name and identity have been established following RM 10212.150C, and the name correction can be processed.

I. Name Correction Because Name on Numident Record Is Not Legal Name

Ramon Garcia applies for a replacement SSN card to show his legal name Ramon Garcia Lopez. He explains he only used his father's last name for many years; however, he has begun using his full legal name again. He submits his birth certificate and driver's license both showing his legal name, Ramon (first name) Garcia Lopez (last name). The birth certificate is evidence of his legal name and his driver's license is evidence of identity. His initial Numident entry shows his name as “Ramon (first name) Garcia Lopez (last name). His last Numident dated January 1980 shows his name as Ramon (first name) Garcia (last name). He completes an SS-5 showing his last name as “Garcia Lopez”, he signs the SS-5 as “Ramon Garcia Lopez”. If all biographical information on the birth certificate and driver’s License agree with the Numident, legal name and identity are established following RM 10212.150C. and the name correction can be processed.