What would you do? We have an existing loan customer who applied to purchase a used truck as a co-signer. The ID verification came back as 'SSN not issued'. The loan was declined and a SAR was prepared. My question, what do I do about the existing customer with a possibly bad SSN. CIP does not apply if I have a reasonalbe belief that I know the customer, but now I do not have a reasonable belief. Should I send the customer a letter to request that he supply us with proof of his SSN? Please help.

We would contact that customer and request verification of the SSN. If it weren't for the loan just being turned down, you could always say you think there is an error in your records and you need to clarify. Not sure what you told the customer about the loan being turned down. If they can't straighten out the SSN we close the account. We have our own reasons for taking that stance. Each bank can make a decision how to handle these situations.

I believe there is a way to verify with the SS Administration if someone's number is valid/issued. If I remember correctly, there is a form that the customer (and maybe the bank) has to sign.

Give your local SS Administration office a call and ask.

There could have been a keying error somewhere along the line. You may want to verify the SSN from the first loan to see if your current number was the same number as the one credit wasobtained on before. (or mis-type??)

You could approach the customer (as suggested) and request to see a copy of the SS card to verify the number was correct. (You would also be helping the customer out if the scenario were legitimate.) If it were closer to tax time, you could ask to see the 1040 form mailed by the IRS. The name and SSN are on the mailing label.

As Dolly notes, there are ways to verify the name/TIN match that rely on source documents rather than commercial data bases. Here's a link to a prior discussion.

I'm reluctant to file SARs in connection with TIN problems. First, because some problems are clerical. Second, because it's difficult to make some problems cross the SAR filing thresholds set out in the regulations. If a customer has a TIN problem, but also has a loan that is "paid as agreed" I would find it hard to conclude that he was attempting to defraud the bank. Repayment goes a long way toward logical verification of identity.

We've run across this ocassionally, especially with recent immigrants. We've found that the SSA has begun issuing certain groups of numbers and that the 3P reporting agencies haven't caught up yet. I would double-check with you customer first on the SSN before filing a SAR. Too often the 3Ps are incorrect.

Does the $5000 threshold need to be met before filing a SAR on someone with a "bad" SSN or one that comes back as invalid on a CTR? When does reporting kick in?