SSN Discrepancy

Question: We opened an account for a customer and collected information required by our Customer Identification Program. When the account was several months old, the depositor made a large cash transaction and we filed a CTR using the SSN that the customer provided and which was on the customer's drivers license. We have just been notified by IRS that the SSN is incorrect. When we contacted the customer to verify this information, she insisted that she gave us her correct SSN. What should we do? Should we file a SAR?

Answer: First, make IRS happy and revise the CTR because that is how they would track or identify the customer. Next, you need to take some steps to resolve this problem. You could file a SAR but you don't really have enough information to establish that this is anything other than a mistake. At this point, we think that filing a SAR is not called for.

However, you do need to clear up the question of which number is correct. You may find, depending on what you learn, that the cause is suspicious. In that case, it may be time to file a SAR. You may also find that the confusion started with a typo or a faulty memory long ago. That certainly would not support a SAR.

To resolve the question of the SSN, it makes sense to start with the customer. The customer already knows that there is a question about the SSN she is using. You might ask the customer to resolve the two-number problem and produce proof to you. If she fails to do that or refuses to do that you can certainly close the account. Give the customer a time limit that is reasonable.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 4, 4/05