States also must be able to verify that the applicant does not
currently hold a valid driver's license in another state and is in
possession of valid identification in support of the driver's license
application. Under section 202(d)(12) of the Act, each State must
provide to each other State(s) electronic access to the DMV database
of that State. There are a number of methods by which this
requirement could be met.

First, the States could simply be left to make whatever arrangements
they choose among themselves. This approach would maximize State
flexibility but could prove burdensome and chaotic in implementation.

Second, the States could create a "federated" or "decentralized"
system, in which each State continues to maintain its own records but
the interface among databases is standardized. This might be
implemented as a "pointer" index that allows States to determine
where to find relevant records about applicants. This system would be
similar to DOT's Commercial Driver's License Information System (CDLIS).

Third, the States could utilize an intermediary, or clearinghouse, to
assemble necessary information about a particular applicant. This
approach would require only one entry of information by a State DMV,
and one transmission of all verifiable information to the
clearinghouse. The clearinghouse would not store data about
applicants; instead, it would determine which databases and systems
to search and then would provide the relevant information once the
data is assembled about that applicant. For example, the
clearinghouse would communicate with SSA to verify the applicant's
Social Security number (submitting the applicant's full legal name,
date of birth and Social Security number provided by the applicant),
submit applicant data through EVVE, submit applicant data to USCIS'
SAVE program as applicable, and check whether the applicant is
licensed in another state through queries to individual States. Once
all these lines of data were verified, the clearinghouse would return
the full, verified response back to the State DMV. In none of these
approaches would a large permanent multistate collection of
individual records be created. The "federated" and clearinghouse
alternatives are focused on the infrastructure among systems, and
would not act as a substitute for the databases that hold the actual
information (i.e., the databases would not "dump" into the
clearinghouse).

 In developing such a system, DHS expects that the all appropriate
privacy and security mechanisms will be included to reduce the risk
of unauthorized access, misuse, fraud, and identity theft. Although
DHS considers the third option to have the highest probability of
timely and effective implementation, DHS will not require States to
adopt one of these approaches as part of these regulations. DHS will
consult actively with States and other stakeholders with a view to
assisting the States in choosing the alternative that is most likely
to reduce the costs of meeting the verification requirement. DHS will
be examining ways in which DHS may assist States in most effectively
meeting the requirements of the REAL ID Act. This may involve
assistance through federal procurements or grants. Any such
assistance will likely be provided separately from this NPRM, but DHS
welcomes comments on the alternatives and on methods by which it may
assist the States in reducing the burden of complying with the
requirements of the REAL ID Act.