We have an existing hispanic customer that has a savings account and consumer loan. He recently came in and applied for a new loan and we noticed the SSN he gave us does not match up to the SSN we have on file. He told us he got the SSN from California so it appears to be a fraudulent number.

We will file a SAR for identity theft. What is the best course of action on his existing accounts?

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I think it would depend on what your CIP Policy/Program says. Because this is a violation of CIP, you found out you don't have a valid TIN or other identifying number (if for non-US citizen), our particular program says that he would need to apply for one, or supply the actual valid number within XX amount of days or we freeze his accounts and ultimately close them if not provided within the required timeframe. I am not 100% about your loan... I am not sure under what circumstances you could call it. I just don't know enough about loans and documentation to know what provisions for that may be included in your agreements.

Another issue I see with this is that somewhere perhaps your own CIP Program/Procedures failed you. I would want to know how the relationship was established in the first place without a valid TIN. Is it an isolated incident or a potential systemic issue? I'd want to get to the bottom of that one and fast.

I just want to clarify that I am assuming *one* of the numbers isn't valid. And if the first one was in fact valid, why would he need to provide a different number the second time he came in...

I am dealing with several instances of this same situation, hispanic individual provides "social security card" with his name and number, and when we run a credit report we get an alert that the SSN may belong to another. A call to local SSA usually yields information that the number does not belong to him. These customers are bringing in bogus SScards. How are we to confirm that the SS number belongs to the individual presenting it? We cannot continually call the SSA, and the SS website's vericiation appears to be intended for employers and not FIs. How are others handling this???

Many ID verification systems will provide the state and year of SSN issuance. As the potential customer when and where the number was issued and compare it to your system response. It's old school but it works.

Then you get to deal with the individual's response..."I know it's good because I just paid $200 for it". (Oh, yes, actual response from a few years back.)