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#1432726 - 08/23/10 04:50 PM Religious Beliefs
dg Offline
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Pacific NW
We have a customer that does not have a social security number based on religious beliefs. Can this be possible? Can we open an account without it, based on this fact?

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#1432754 - 08/23/10 05:27 PM Re: Religious Beliefs dg
Retread Offline
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Retread
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Go to http://files.ots.treas.gov/480259.pdf and see question E2.
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#1432863 - 08/23/10 07:56 PM Re: Religious Beliefs Retread
Elwood P. Dowd Offline
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Where do you find this stuff?! The answer is correct, but do you consider the OTS a credible source? grin

The Amish can obtain a number and then opt out of SS straightaway. It's not the number that violates their beliefs, it's participation in a society other than their own.
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#1433074 - 08/24/10 10:58 AM Re: Religious Beliefs Elwood P. Dowd
Retread Offline
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"Where do you find this stuff?! The answer is correct, but do you consider the OTS a credible source?"

Part of my job is to find anything to prove in writing that examiner criticisms may be totally wrong. If the source happens to be OTS, then they are credible. Otherwise, I sometimes have my doubts.

If the OTS info fails, there is always this as a possible reason for not providing a SSN. http://sedm.org/Forms/Tax/Withholding/WhyTINIllegal.pdf

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#1433238 - 08/24/10 02:51 PM Re: Religious Beliefs Retread
kw004h Offline
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Chicagoland, IL
Wow.

That is all. Just, wow.

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#1433241 - 08/24/10 02:54 PM Re: Religious Beliefs kw004h
Georgia Plum
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Good Gawd Awmighty. Quadruple WOW.

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#1438389 - 09/02/10 06:10 PM Re: Religious Beliefs
dg Offline
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Pacific NW
Ok, so theres alot of reading here for me to do. But I have a customer that does not have a SSN and insists on opening an account. We have not been faced with this before and therefore have no procedures in place. What are others doing? Are you opening these accounts and if so what documents are you obtaining? Are your CIP procedures tweeked for these types of accounts?

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#1438392 - 09/02/10 06:12 PM Re: Religious Beliefs dg
Skittles Offline
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TN
We would not open the account here.
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#1438401 - 09/02/10 06:15 PM Re: Religious Beliefs dg
M Cockrell Offline
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Dallas, TX
For us: no SSN = NO DDA

see 31 CFR 103.121(b)(2)(i)(A)(4)

31 CFR 103.121(b)(2)(i)(B) provides an exception, IF your CIP procedures allow for obtaining and verifying a SSN after opening an account PROVIDED you obtain proof that the customer (to be) has at least applied for, but not yet received his/her TIN.
Last edited by M Cockrell; 09/02/10 06:37 PM. Reason: added info
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#1438402 - 09/02/10 06:15 PM Re: Religious Beliefs dg
Elwood P. Dowd Offline
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If this individual is a U.S. citizen, you simply cannot open the account without a U.S. issued taxpayer identification number. No special policies or procedures can get you around that fact.

Banks are often accomodate religious beliefs in their identification requirements, but the individual must have a TIN before you even get to the verification process.

It's a matter of personal conscience for the individual as to whether he wants to get an SSN and then opt out of the Social Security system. Some do. Some do not.
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#1438407 - 09/02/10 06:19 PM Re: Religious Beliefs Elwood P. Dowd
M Cockrell Offline
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Originally Posted By: Ken_Pegasus
It's a matter of personal conscience for the individual as to whether he wants to get an SSN and then opt out of the Social Security system. Some do. Some do not.

And, that choice comes with consequences. One of them being, no bank account.

No one's going to force them to get an SSN, but that doesn't mean they're allowed to foist the repercussions of their decision upon you, making it your problem.
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