TN 149 (01-25)

GN 00307.101 Name Discrepancies Involving Foreign Evidence

A. Introduction to resolving name discrepancies involving evidence

Name discrepancies occur when the name on a proof of identity document differs from the name in our records. The Modernized Claims System (MCS) alerts technicians in the claims path when there are name discrepancies. Development of the name discrepancy depends on whether the name discrepancy is immaterial (minor) or material (major). Refer to GN 00307.101B in this section for definitions. Resolve discrepancies before adjudicating the claim.

For instructions on identifying claimants who file an application, see GN 00203.020. For resolving name discrepancies in claims involving domestic evidence, see GN 00203.030.

B. Definitions related to name discrepancies involving evidence

  1. 1. 

    Given name: All, or any part, of a name (including a middle name) except the surname.

  2. 2. 

    Immaterial (minor) discrepancy: The name discrepancy is obvious, easily explainable, and raises no doubt that the record pertains to the claimant.

  3. 3. 

    Material (major) discrepancy: The name on the record is so different from the one the claimant now uses that it raises doubt about whether the document pertains to the claimant.

  4. 4. 

    Surname: The family name or last name that distinguishes members of one family from members of another.

C. Types of immaterial, or minor, name discrepancies

The following chart contains examples of immaterial, or minor, discrepancies. Note that other types of immaterial (minor) discrepancies exist.

Type of Difference

Additional Information and Examples

Different spelling of the same name

  • Smyth vs Smith

  • Jonathan vs Johnathan

  • Mary Ann vs Marianne

Nickname commonly derived from the name

  • Gio vs Giovanni

  • Leo vs Leonardo

  • Alex vs Alexander

English equivalent of a foreign given name

  • Alice vs Alicia

  • William vs Wilhem

  • Paul vs Paulo

The following guide provides useful information about names and naming practices around the world: https://www.fbiic.gov/public/2008/nov/Naming_practice_guide_UK_2006.pdf

NOTE: Construction of foreign names varies from culture to culture. For example, certain countries’ birth certificates display names in this order: surname, middle name, given name. This format contrasts with most birth certificates issued in the United States (U.S.), which display names in this order: given name, middle name, surname. For more information, refer to https://www.uscis.gov/policy-manual/volume-1-part-e-chapter-5#.

Simplified versions of surnames

  • Malinow vs Malinowski

  • Burgdof vs Von Burgdof

    NOTE: Be careful when assessing the difference in a person's surname. If the surname on the record is very different from the one the claimant uses (e.g., Jelieniweski and Jelen; Abramowitz and Abrams) the discrepancy is major (see GN 00307.101D in this section).

Compound Surname

  • Sanchez Diaz vs Diaz Sanchez vs Sanchez vs Diaz

  • Calbo Ortes vs Ortes Calbo vs Ortes vs Calbo

NOTE: Compound surnames may occur as a result of marriage of the individual or may reflect the surnames of both the individual's parents.

Amended birth or religious record by the official custodian to add an omitted given name, or to change a given name

The difference is immaterial (minor) if:

  • The custodian amended the record at least five years before the current filing date; or

  • The record shows a more recent amendment based on a five-year-old (or older) document; and

  • In the case of a given name change, the record shows the basis for the change.

    NOTE: When the amended record is for a child who is under age five, the supporting documentation shown on the record may be less than five years old.

    However, where there is no supporting documentation for the addition of a name for a child under age five, or where the custodian amended the birth record recently based on recent evidence, the discrepancy is material (major). (See GN 00307.101D in this section).

D. Types of material, or major, name discrepancies

The following list contains examples of material, or major, discrepancies. Note that other types of material (major) discrepancies exist.

Type of Difference

Examples

No given name

  • No given name

  • No first name (NFN)

  • First name unknown (FNU)

  • Baby Girl

  • Baby Doe

Given name is different and the basis for the change is not shown

  • David Pierre vs John Pierre

  • Samantha Martinez vs Nancy Martinez

  • Sara Jo Clay vs Mary Jo Clay

Given name is different and the basis is a document less than five years old

  • Marquis Abundi vs Marion Abundi

  • Natasha Hernandez vs Rebecca Hernandez

Surname is different and is other than a simplified foreign surname (see GN 00307.101C in this section)

  • John Vallejo y Vazquez vs John Cortez

  • Don Giovanni vs Don Leon

  • Alex Carsholton vs Alex Carollton

E. Procedure for resolving immaterial, or minor, name discrepancies

Document your review and the reason you determined the name discrepancy to be immaterial (minor) on Form SSA-553 (Special Determination), see GN 01010.360.

EXAMPLE: The applicant presented a passport in the name of Paul Fabio. Our records show the individual’s name as Pablo Fabio. When asked about the discrepancy, the applicant explained they used the name Paul, as it was more easily understood. We determined the name discrepancy is minor and matched the DOB on the passport to the DOB in our records to establish the claimant’s identity.

NOTE: If you are not sure whether a difference is material (major) or immaterial (minor), treat the difference as material (major). Refer to GN 00307.101D in this section.

F. Procedure for resolving material, or major, name discrepancies

  1. 1. 

    Identify and document the allegation and explanation of the name discrepancy

    • Compare the identification information on the evidence and our records (i.e., name, date of birth, parent’s names, etc.). Examine the Numident, Master Beneficiary Record (MBR), Modernized Claims System (MCS), etc.

    • Document discrepancies between the evidence and our records on the RPOC screen in MCS, or on a Form SSA-5002 (Report of Contact).

    • Document the allegation and explanations for the claimant’s name discrepancy in the claims path, or on a Form SSA-5002 (Report of Contact).

  2. 2. 

    Determine whether to request additional documentation to explain the name discrepancy

    If

    Then

    The DOB on evidence presented matches the DOB in our records

    Continue to F.3 in this section and document the supporting evidence and determination made.

    The DOB on evidence presented does not match our records

    Obtain a document recorded at least five years before the current application filing date that clearly belongs to the claimant and matches the DOB in our records in order to verify the name discrepancy.

     

    NOTE: When an amended record is involved for a child who is under age five, the supporting documentation may be less than five years old.

    • If a claimant needs assistance in obtaining sufficient evidence, make every reasonable effort to assist them, per GN 00301.180.

    • If able to obtain evidence to resolve the name discrepancy, continue to GN 00307.101F.3 in this section and document the supporting evidence and determination made.

    • If unable to resolve the discrepancy after making every reasonable effort to assist the claimant in obtaining evidence, deny the claim following procedures in GN 01010.410.

    There are multiple name discrepancies (e.g. aliases)

    • Obtain an SSA-795 Statement of Claimant or other Person) from the claimant to explain various names

    • If a claimant needs assistance in obtaining sufficient evidence, make every reasonable effort to assist them, per GN 00301.180.

    • If able to resolve the name discrepancy, continue to GN 00307.101F.3 in this section and document the supporting evidence and determination made.

    • If unable to resolve the discrepancy after making every reasonable effort to assist the claimant in obtaining evidence, deny the claim following procedures in GN 01010.410.

    NOTE: Do not resolve a name discrepancy if it appears on a document that would not, even if corroborated, influence your determination.

    EXAMPLE:The claimant applied under the name Michaela Robertson. A birth certificate and passport were submitted with the application. The birth certificate shows the name Michaela Brown. The passport shows the name Michaela Robertson and was issued 2 years before the application filing date. Do not use the passport to resolve the name discrepancy. Obtain a document recorded at least five years before the current application filing date that clearly belongs to the claimant and matches the DOB in our records in order to verify the name discrepancy.

  3. 3. 

    Document the determination

    Document the claimant’s explanations for the name discrepancy, supporting documentation, and the determination made on a Form SSA-553 (Special Determination).

    NOTE: A simple statement of opinion, such as "I believe the birth record presented belongs to the claimant", is not sufficient. Document the rationale for concluding that the record pertains to the claimant.

    EXAMPLE: The claimant applied under the name Martín García. The birth certificate (BC) provided shows the name Martín García Florez. The DOB on the BC matches our records. Interview with the claimant identified that they used a traditional compound surname when they entered the U.S., but now use only their father's surname.

    The following explanation would be adequate: "Claimant used mother's surname (García) on the application. The claimant's mother's name in our records is Carla Rodriguez García. Since other identifying information matches the information in our records, we assume the record pertains to the claimant."

    EXAMPLE: The claimant applied under the name Frank De Caker. The passport provided shows the name Florigio De Caker. The DOB on the passport is October 5, 1945. The DOB in our records is October 15, 1945. Because we cannot use the DOB to verify the claimant's identity, we requested additional documentation. The claimant provided a BC with a DOB of October 15, 1945, which matches our records. Interview with the claimant identified that when their family immigrated to the U.S. they registered their given names as the English equivalent of their Italian given names.

    The following explanation would be adequate: “When the claimant’s family immigrated to the U.S. they registered their first names as the English equivalent of their Italian given name. We used the DOB on the BC to establish the claimant's age. Since the identifying information matches the information in our records, we assume the record pertains to the claimant.”


To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0200307101
GN 00307.101 - Name Discrepancies Involving Foreign Evidence - 01/07/2025
Batch run: 01/07/2025
Rev:01/07/2025