2023.False Financial Statement: Use of False Identifying
Information (Pen. Code, § 532a(4))
If you ﬁnd the defendant guilty of ((making/ [or] causing to be made) a
false written statement as charged in Count [,]/ [or] obtaining a
beneﬁt using a false written statement as charged in Count [,]/
[or] representing as true a false written statement as charged in Count
), you must then decide whether the People have proved that the
defendant used false identifying information.
<Alternative A—ﬁctitious information>
[To prove this allegation, the People must prove that the defendant used
a ﬁctitious (name[,]/ [or] social security number[,]/ [or] business
name[,]/ [or] business address).]
<Alternative B—represented self as someone else>
[To prove this allegation, the People must prove that the defendant
falsely (represented that (he/she) was someone else/ [or] claimed that
(he/she) represented a business when (he/she) did not).]
The People have the burden of proving this allegation beyond a
reasonable doubt. If the People have not met this burden, you must ﬁnd
that this allegation has not been proved.
New January 2006
If the defendant is charged with a felony based on using false identifying
information, the court has a sua sponte duty to instruct on this sentencing factor.
This instruction must be given with the appropriate instruction on the other
elements of the offense, CALCRIM Nos. 2020 to 2022.
The court must provide the jury with a verdict form on which the jury will indicate
if the prosecution has or has not been proved that the defendant used false
CALCRIM No. 2020, False Financial Statement: Making False Statement.
CALCRIM No. 2021, False Financial Statement: Obtaining Beneﬁt.
CALCRIM No. 2022, False Financial Statement: Reaffırming Statement.
• Elements. Pen. Code, § 532a(4).