TN 18 (04-20)

PR 02706.080 Bahamas


Date: February 13, 2020


For enumeration purposes, a Bahamian marriage document is not acceptable evidence of a legal name change event. Applicant must provide acceptable evidence of a legal name change such as a U.S. marriage document or U.S. court order (for addition information see chart in RM 10212.010).


a. Question Presented

You requested a legal opinion regarding whether a Bahamian Maritime marriage document can serve as evidence of a name change for the purpose of processing a replacement Social Security Number (SSN) card application for E~ K~.


No, the Bahamian Maritime marriage document does not constitute acceptable evidence of a name change under Social Security Administration (SSA) policy.


In September 20XX, Ms. K~, a resident of Indiana, submitted an application for a replacement SSN card. She requested that her surname be changed to “N~,” based on her marriage to G~N~.

We were provided a photocopy of Ms. K~’s marriage certificate. The certificate described a July, 20XX marriage ceremony between Ms. K~. and Mr. N~. aboard the ship Allure of the Seas in Bahamian waters (coordinates 22°31.8’N, 077°58.4’W). According to the certificate, the ceremony was officiated by Master R~ H~ and was witnessed by S~ L~ and N~ F~.

This document indicated that it was a “true Copy of an Entry in the Register of Maritime Marriages” and a public document issued by the Commonwealth of The Bahamas. The marriage certificate was signed by S~ R~, Acting Assistant Registrar General of the Commonwealth of The Bahamas, and certified by O~ W~-S~, First Assistant Secretary Ministry of Foreign Affairs of the Commonwealth of The Bahamas.


Social Security regulations provide that a number holder may request a change in personal identifying information, including the name, on his or her SSN card. See 20 C.F.R. § 422.110. Specifically, to process a name change on the SSN, SSA must obtain evidence of: 1) a name change event; 2) the new name; and 3) the number holder’s identity as shown on the latest Numident record. POMS RM 10212.015. When the name change event is a foreign marriage, foreign marriage documents must be evaluated under the guidelines for reviewing SSN evidence in POMS RM 10210.210, as well as those for evaluating foreign evidence in POMS GN 00307.000. See POMS RM 10212.010, RM 10212.050.

The POMS section governing evidence from The Bahamas states that SSA does not accept evidence from The Bahamas “at face value,” because such evidence is not reliable. POMS GN 00307.440. In particular, this section indicates that Bahamian “marriage records have relatively few security features and are easy to forge.” POMS GN 00307.440A. This section further instructs:

Do not ask the claimant to submit evidence from the Bahamas. Develop for secondary non-Bahamian evidence or other non-Bahamian evidence. Obtain evidence issued at least five years before the claimant first filed for benefits. If the event occurred less than five years before the claimant first filed for benefits,obtain evidence issued as close to the event date as possible.

POMS GN 00307.440C.2.

In addition, agency policy provides that when a document is determined to be unacceptable evidence of a name change, SSA will attempt to obtain “available evidence of the highest probative value based on the SSN requirement factors for evidence.” POMS RM 10210.210 (“Step 2”). As a result, an applicant who wishes to change the name on his or her SSN based on a Bahamian marriage may have to provide another document that is acceptable evidence of a name change event, based on an event listed in POMS RM 10212.010.

In this case, Ms. K~ submitted a marriage certificate from The Bahamas in support of her request for a name change on her SSN. However, because this document is Bahamian evidence, it is not an acceptable name change document under SSA policy. POMS GN 00307.440B. We were not given any information as to whether the Field Office has developed for secondary or other non-Bahamian evidence of Ms. K~’s name change. POMS GN 00307.440C.2. Thus, based on the materials provided, we do not believe there is sufficient evidence of a name change event as required to process Ms. K~’s name change.

We note that there appear to be other ways that Ms. K~ may change the name on her SSN card. See POMS RM 10212.010. For example, she may obtain a U.S. court order of name change. See POMS RM 10212.080, RM 10212.085. In Indiana, certain courts may change an individual’s name upon petition, provided he or she is not confined to a department of correction facility or a lifetime sex or violent offender (unless certain other circumstances apply). See Indiana Code §§ 34-28-2-1, 34-28-2-1.5. Alternatively, Ms. K~ may obtain a U.S. marriage certificate. See POMS RM 10212.025, RM 10212.055. She would also need to submit evidence of her identity, as required by POMS RM 10212.015D.


For the reasons discussed above, we conclude that the marriage certificate provided is not acceptable evidence of a name change under SSA policy.

Kathryn C~

Regional Chief Counsel

Eric Y ~

Assistant Regional Counsel

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PR 02706.080 - Bahamas - 04/14/2020
Batch run: 04/14/2020