In doing research on valid/invalid SSN numbers, for our CIP procedures, I came across a number of articles (probably not very credible, and/or written by guys who own their own Kevlar vests) that claim that it is illegal to demand a social security number. One particular 250-page online booklet has a number of forms the reader can use to attempt to persuade the institution to open an account without obtaining an SSN or TIN. They argue that the law requires the institution to request the TIN, but that the law does not require the customer to provide it. They offer "how-to" guides on taking legal action against institutions who "illegally demand" SSNs/TINs. Have any of you had a customer threaten to sue you, for demanding an SSN? Has the customer taken it as far as securing the services of a lawyer?
The only case I have seen lately where we didn't get the SSN was for one of the three signers of a local business account (not exempt from CIP). We had the TIN of the business, but one of the signers refused to provide his SSN, citing the Privacy Act. Regulation, and our policy, only requires us to "identify" the customer itself - the business - and our policy says we will obtain as much info as possible regarding the signers. I draw the "possible" line right about where the (non-customer) account signer refuses to give up his SSN. Ditto for unsuccessful attempts to collect this information from non-customer payees who cash checks in amounts of under $10,000 at our institution.
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"It is natural to give a clear view of the world after accepting the idea that it must be clear." - Albert Camus