We have an existing customer opening a safe deposit box, along with two relatives of hers, both of which are new customers to the bank. Bank requested CIP information for these two relatives, however one of them refused to give us his SSN. His reasoning is that his employer (a government agency) has told him not to give his SSN to anyone. How do other banks handle this type of situation? Thanks.

This is the same government that told us that we could not open an account without a US Identifying Number?

Seriously though, we have had one case and it was someone in an undercover position, - it was substantiated - and he gave the Security Officer the SSN but we did not put it on the system.

Never had that happen yet but I would refuse the customer who declined to give us their number.

We have not had it happen either but we would als refuse the customer as well.

Don't open an account or add a person on account or safe depsoit box without ss #. It just won't happen here.

Two words for the consumer (not yet a customer) refusing to provide the SSN:

Buh Bye

No SSN, no account. KISS.

What if you need to file a CTR? Do you refer to the Security Officer. If the SO leaves the bank, does he/she give it to someone else? It's just an accident waiting to happen IMHO.

Since you said a customer brought in some relatives, I'd say it's a safe bet that its not a government account. Unless the box itself is opened on behalf of a government agency and he is acting in his capacity as a representative of that agency, he is not exempt from CIP. If he personally is going to be the customer, you need to CIP him.

Just say no!

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.

How about this from http://www.ustreas.gov/press/releases/js335.htm

See Fact sheet