The first time the policy is invoked, the security policy will check the last password date, which appears to come...
from the notes.id file rather than from the person document, as you have indicated. If the last change date is greater than 90 days, then the security policy settings are applied.
In my experience, if you are going to implement security settings via policy documents, it is best to remove the previous process -- that is, standard password checking through the Domino Directory -- and then apply the security policy once password checking (i.e., Domino Directory, "Actions" menu, "Set Password Fields," "Don't Check password") has been disabled.
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