The requirement of a list of accounts without TINs applies to accounts opened prior to 10/1/2003. The regulation requires that you obtain a TIN (or other identifying number for non U.S. citizens) for all accounts opened after 9/30/2003. So the reg doesn't anticipate a need for these accounts to be included on a missing TIN list.
There is a provision in the new regs that permits you to open a "pending TIN" account, but only if you are sure a TIN has been applied for. And you are required to have a procedure for force-closing such accounts if a TIN is not received within a reasonable amount of time. As someone has suggested, following up on "pending TIN" accounts may be more trouble than it's worth, so some banks are using a "no TIN, no account" approach.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8