No, the paper extension allows them to legally drive, but by itself, it doesn't have all the requirements for an ID under CA notary law, specifically a photo. I checked on that with the SOS office years ago, just to be sure, and that's what I was told. Further, I also don't believe it meets all the requirements for use of credible witnesses, either. Unless there were extenuating circumstances, like the person had been out of the country or hospitalized, etc., the fact that they just didn't get their DL renewed in time, IMO doesn't meet the "difficult or impossible" requirement.
As we've discussed here before, the CWs are the ones who have to state under oath that the requirements for use have been met, but I also believe that we have a choice as to whether or not to even offer that as an option. BTW, when I accept CWs, I not only have them sign in my journal, I have them sign a document I created ages ago that spells out all the preconditions for CW use. I have them read the contents first, or more often than not, I read it to them out loud, THEN I administer the oath.
Having said all that, when you're dealing with loan docs, you also need to be sure that the lender will accept the use of CWs (or a paper extension...) This could lead to a delay, maybe even a redraw.
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