What number should be used when filing a CTR on individuals that only have an ITIN good only for work purposes with INS authorization? We have filed them using that number and they've been returned. How else would you file them?

According to the CTR instructions, the ITIN is acceptable:

Item 6. SSN/ITIN or EIN. Enter the Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN) or Employer Identification Number (EIN)of the person or entity identified in Item 2. If none, write NONE.

Specifically, what reason are they giving you for kicking the CTR back?

It may be that the ITINs you are being provided are simply "composed" on the spot. All the offeror would have to do is come up with a nine digit number beginning with a "9" unless you require a copy of the letter from the IRS awarding the number.

They say that the SSN or EIN does not match their file of valid SSN/EIN's. I have a copy of her card that says "valid for work only with INS authorization" and the number reported is correct.

I suggest you send the Data Processing Center a copy of the card in response to the correspondence and ask for further instructions. Beyond that, there really isn't anything you can or should do. (Your examiners will ask for copies of your CTR related correspondence.)

Another source for verifying the number would be the TIN matching service ( prior thread), but a single instance will not justify the effort involved in registering.

Thanks for the information!

When names and TINs don't match also consider that the NAME supplied was incorrect. It's not always the TIN that is the issue.

You may want to require non-customers to show their card before you permit them to conduct a transaction that requires a CTR.