I haven't found a post that quite helps with this. We have customers since 1998 who recently asked us to change their social security numbers in our records. They presented documentation from the social security administration that evidences their application for new cards. We also have copies of their 2004 tax returns that indicate the new or different social security numbers. They told us their attorney suggested they request new numbers. The call to the attorney only let us determine that the attorney handles immigration issues. We have filed a SAR. We would like to close the accounts - 9 of them. Is there any other action we should take?

Are these individuals that have recently become eligible for a SSN? It could very well be that the previous number they had was an ITIN. If an individual has an ITIN and becomes eligible for a SSN - they are required by law to file for the new SSN.

I would be sure I had my ducks in a row before filing the SAR and taking other action.

On the other hand, if you have proof that the previous numbers where a misrepresentation or stolen, then by all means - file the SAR and I would close the accounts.

Unfortunately, the numbers were not ITINs and the numbers were not those of our customers. We find it hard to understand why there wasn't a conflict with the IRS with tax or interest reporting.

I take it these accounts were opened prior to you implementing your CIP program?? You may very well get B notices sometime in the future.

Randy, you are correct, we opened these accounts before CIP. What is a B notice?

A B notice is what you receive from the IRS when you report interest on a person and the name mismatches the SSN or ITIN.

Actually, I think they are now called a CP2100. See below:

Backup Withholding

Thank you for your help.

You say these accounts were opened in 1998. You would think you would have had a notice by now if one was coming!

Are you even sure these are SSNs? Some of these so-called credit repair services have their "clients" apply for EINs and use those as if they were SSNs so their bad credit does not show up when a prospective creditor runs a credit check. That's how they "repair" the credit.

I would be suspicious of this activity. The Social Security Administration is not eager to "Change" social security numbers. They don't do it just on a whim or for any old reason. When I adopted my daughter, I wanted to have her SSN changed in the event that her birth parents still had her SSN. They refused to allow it stating that the laws had changed early in 2004 and that actual ID theft had to occur prior to allowing a SSN change. Extraordinary circumstances have to exist prior to their taking this action. SO... I would wonder if the original SSN belonged to the customer.

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The Social Security Administration is not eager to "Change" social security numbers.

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That's correct and, even when identity theft has taken place, SSA still advises against it. Ask the customer why the numbers changed. Any answer other than "identity theft" or witness protection is probably a nonstarter.

It is possible to file 1099's on an incorrect name/TIN combination and not get a B Notice. The IRS uses "filters" on B Notices; i.e. what's it going to cost us to send the notice vs. what is the amount of additional revenue would it would generate. The amount of the filter is secret, but at one time a client demonstrated to me that a 1099 for less than $300 did not generate a B Notice.