Page 1 of 2 1 2
Thread Options
#147027 - 01/08/04 04:05 PM Invalid SSN
Queen Mum Offline
Power Poster
Queen Mum
Joined: Mar 2001
Posts: 3,920
OK
We had an interesting event a couple of days ago. A customer came in for a loan. We ran the customer through the verification system and it came back saying invalid SSN. Upon further investigation, it was determined that this number is assigned to the New York area and is in the block of numbers that has never been issued. The customer had a SSN card (well-worn), insurance card and a Kansas driver's license. He said he has lived in Oklahoma for 3 years and he works for a local company. Oh, the customer is definitely Hispanic. The loan officer went ahead and made the loan and I had the secretary note that CIP could not be verified but officer approved loan.

Return to Top
BSA/AML/CIP/OFAC Forum
#147028 - 01/08/04 04:32 PM Re: Invalid SSN
Anonymous
Unregistered

Having worked in SW kansas for several years, we saw our share of forged SSN cards. It was very commonplace. Our policy was we did not process accounts on anyone that had a hawk alert indicating the SSN was not valid. Our main concern being if in fact this individual was other then a united states citizen and the loan went into default, we had no recourse in mexico, (which is where most of them fled when the loan went bad).

Return to Top
#147029 - 01/08/04 04:39 PM Re: Invalid SSN
renniks Offline
Diamond Poster
renniks
Joined: Sep 2003
Posts: 2,162
New England
Boomermom, we had a similar situation and did not approve the loan. We used the adverse reason of "Unable to Verify Identity".

Return to Top
#147030 - 01/08/04 04:59 PM Re: Invalid SSN
Anonymous
Unregistered

What do you mean by the remark, "Oh, the customer was definitely Hispanic." I'm trying to understand this significance to your issue -- which was the need to dig deeper to validate the Social Security number.

While anyone would concede that Hispanic surnames (primarily indigenous to Mexico and Colombia) are disproportionately represented in OFAC/PATRIOT listings, the borrower's ethnicity was not relevant here. Anyone dealing with Social Security numbers knows that there are many duplicate numbers, re-issue errors, and other factors; and the best way for you to easily and quickly cure the identifier question would be to have the borrower/customer bring you various source documents showing that same Social Security number. A consumer who is viably employed will, and should, have a valid SS# with their employer, and that number can be verified; the consumer may have past loans and/or deposits that are now closed, and documents can be provided to you, which show the reported SS#. Finally, federal tax filings and, if needed, having them sign IRS Form 4506 to get the tax documents released to show what SS# they're filing under, can provide you with verifying information.

Presumably if you were making a loan -- and you apparently did make the loan -- you could also validate the SS# when you obtained the credit report and conducted the underwriting assessment.

In making a loan and your not sure of the SS#, there is no rush and you have plenty of avenues to go in. Also, I can understand your concern if this is a personal loan (with no collateral), but if you have collateral pledged then I think you can generally assume this is not a high risk. The terrorists aren't getting home-equity loans; they're trying to open DDA, deposit or wire accounts that permit movement of cash to the U.S.

Absent any other indicators of a high-risk scenario, your mere mentioning of the borrower's etnicity as though it is part of your risk model is troubling. I would not be so quick to share this.

Return to Top
#147031 - 01/08/04 05:38 PM Re: Invalid SSN
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I took the reference to ethnicity as suggesting the most likely explanation for why the bank was willing to make the loan even though the applicant did not have a valid SSN. It is no great surprise that a number of Mexican nationals are in the United States illegally and that banks are nevertheless accomodating their financial needs. Personally, I think the bank should have made a different decision.

Nevertheless, in order to see the the reference as a slur which I would be above making, I would need to be sitting on a high horse. In order to criticize it here, I would need to post anonymously.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#147032 - 01/08/04 07:26 PM Re: Invalid SSN
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
I think boomermom made the comment because it is so well known that hispanic customers share social security numbers, use phony social security numbers, etc. If there is a social security number problem there is a high likelyhood you are dealing with a hispanic.

Be brave..........sign up and don't post as anon.

Return to Top
#147033 - 01/08/04 07:36 PM Re: Invalid SSN
Lestie G Online

Power Poster
Joined: May 2002
Posts: 3,606
Near the Land of Enchantment
Quote:

I think boomermom made the comment because it is so well known that hispanic customers share social security numbers, use phony social security numbers, etc. If there is a social security number problem there is a high likelyhood you are dealing with a hispanic.




I've lived and worked in predominantly Hispanic areas all my life. I've never thought that, or even heard it. I've seen cases where Mexican Nationals were convinced that using false information would keep them in the US, but those cases are very small in number. Hispanics are no more or less likely to commit this type of fraud than anyone else!

Please don't paint an entire community of people with the same brush!
_________________________
Opinions my own.

Return to Top
#147034 - 01/08/04 08:15 PM Re: Invalid SSN
Jokerman Offline
10K Club
Joined: Nov 2003
Posts: 12,846
79% of illegal aliens (who would be quite unlikely to have a valid SSN) are from Mexico or Central America, according to US Government estimates. A person noting the ethnicity of a person with a questionable SSN is simply cognizant of that fact, and does not imply that all Hispanics are guilty of this.

How many bank security programs note that bank robbers are overwhelming likely to be male? Anyone ever show a training video that has a female perp? No?

Sexists!!!

Return to Top
#147035 - 01/08/04 08:28 PM Re: Invalid SSN
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Lestie G...this may not be the case in your area but it sure is in mine. I'm only stating a very well known fact. Enough said!

Return to Top
#147036 - 01/08/04 09:21 PM Re: Invalid SSN
Queen Mum Offline
Power Poster
Queen Mum
Joined: Mar 2001
Posts: 3,920
OK
I think you all have me pegged wrong. The only reason I mentioned that he was Hispanic was to further question the validity of the SSN. We have a large contingency of Hispanics in our area. They come straight up from Mexico through Texas. Remember I said the SSN was issued from New York State. Now, I don't know about you, but it seems strange that someone would travel to New York and get a SSN and then end up back in the mid-west where he has supposedly lived a long time. It just made me question it even more. If I were back east I might question the same of someone with a distinct European accent that had a SSN issued from Oklahoma.

Return to Top
#147037 - 01/08/04 09:59 PM Re: Invalid SSN
Just Jean Offline
Platinum Poster
Joined: Feb 2002
Posts: 582
USA
According to our local police, an illegal alien usually purchases a complete set of documents to use while in this country. The names and numbers are frequently "recycled". We have seen the same name, DOB, SSN etc on multiple persons.

Return to Top
#147038 - 01/08/04 10:14 PM Re: Invalid SSN
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,402
Florida
Right now, I'm dealing with a QC issue where two independent verifications have come back that the "Input SSN have not been issued as of 12/03".

The next step (since the applicants have been at the same job for 2 years) is to have them sign a 4506 and see if the IRS has a record of the returns filed under the SSN's.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#147039 - 01/08/04 10:16 PM Re: Invalid SSN
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Jax, they should also receive a form 1040 through the mail in the next few days. Ask them to bring it in with the pre-printed label.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#147040 - 01/08/04 10:34 PM Re: Invalid SSN
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,402
Florida
Quote:

they should also receive a form 1040 through the mail in the next few days.


Thanks for the reminder. After our request, I have a bet the'll "withdraw" the loan.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#147041 - 01/08/04 10:46 PM Re: Invalid SSN
Queen Mum Offline
Power Poster
Queen Mum
Joined: Mar 2001
Posts: 3,920
OK
There is a way to use the Social Security website to determine if a number has been issued. It's takes a few steps, but if anyone wants to PM me and send me their e-mail, I will send the link and try to explain it.

Return to Top
#147042 - 01/08/04 11:38 PM Re: Invalid SSN
Anonymous
Unregistered

Boomermom - Nobody is trying to peg you incorrectly, and it is understood why your interest would be piqued -- because, as was previously noted, a disproportionate number of fraudulent situations and other OFAC-related issues involve Hispanics. I'm aware of all that.

In your situation, however, you have a loan that you state your bank DID ultimately make to the borrower. Though you don't say what type of loan, I have to believe that the loan officer was ultimately satisfied that the unique identification of the borrower was established -- or else why would you be making unsafe/unsound loans. Therefore, noting that the borrower was Hispanic was a gratuitous remark. Assuming you are a compliance/risk person, you would know that there are many available options for validating an individual's identity -- again, a point noted previously.

Your error in judgement is minor compared to the so-called diamond discussers who offer useless drivel and lament over anonymous postings instead of offering mature, helpful discussions related to nondiscrimination in lending and other services; nondiscrimination in applications; and the existence of illegal disparate treatment. Because you noted that your institution HAD extended credit to the borrower, I was noting that your remark regarding the borrower's ethnicity was not relevant to the process for validating the applicant's identity and social security number. Again, your loan officer would have ample time to obtain numerous proof-of-identity documents prior to disbursing any funds -- and based on the loan having been made, this must have happened.

I have no axe to grind, and I'm not Hispanic nor an alien, but the respondents to your post are not the experienced posters who would have referenced the overt evidence of statements revealing explicit consideration of prohibited factors. Some of the posts use the uncapitalized term hispanic (sic); make other gratuitous references; and don't address the primary issue which is how your institution should address identity verification and validation when instances occur such as the questioned Social Security number. It is acknowledged that there is Social Security-card abuse, illegal immigration, and other bad things, but you made the loan. The Hispanic comment was and is gratuitous.


Return to Top
#147043 - 01/09/04 06:02 AM Re: Invalid SSN
cbinder63 Offline

Platinum Poster
cbinder63
Joined: Dec 2001
Posts: 674
Colorado
When there is a mismatch or validation error on Social Security Numbers, often you can call the local Social Security Office and they will verify the name to the number.
_________________________
Opinions expressed are my own.

Return to Top
#147044 - 01/09/04 04:22 PM Re: Invalid SSN
Queen Mum Offline
Power Poster
Queen Mum
Joined: Mar 2001
Posts: 3,920
OK
FYI - we have tried calling the Social Security Office for verification and they will not give out information except to the holder of the SSN in question.

And Anon, since you do not care to identify yourself, your remarks are taken lightly. Think what you want.

Return to Top
#147045 - 01/09/04 05:35 PM Re: Invalid SSN
Anonymous
Unregistered

Your story is just not credible anymore. Why would you now being calling the Social Security Administration when you've conceded your institution already extended credit to the borrower. The loan would not be sound if your institution did not establish the unique identity of the applicant prior to disbursing the loan proceeds.

There is no industry or regulatory pressure for any FFIEC- or state-supervised institution to extend credit to any individual where that person's true identity cannot first be validated. I can understand an institution opening a deposit account and putting a hold on the account until the verification/validity is completed, but I can't understand how an institution would extend credit to a loan applicant without this done. That your institution had an individual who ultimately was extended credit by a competent lending officer -- meaning a credit report was obtained, employment was verified, a mail address was obtained -- leaves me to believe that you fabricated the scope of the actual event, and your comment, " Oh, the customer is definitely Hispanic." was made for effect. You knew credit had been extended to the customer when you made the remark. My reply was that the remark is not one that should be shared, obviously because it is a remark that clearly indicates the existence of illegal disparate treatment through your statement -- made in your post -- that your institution explicitly considers prohibited, overt factors and different treatment for Hispanics.

My original point, made clearly, was that the main underlying issue should be for you to devise systematic, consistent incident response-type procedures or steps to address what you should do for any individual -- white, African-American, Hispanic, Asian, Native American -- whose identity is called into question.

You won't concede that your remark was unwarranted, and that it was done for effect to generate more posts that further generalized untrustworthiness of Mexicans/Hispanics, aliens, etc. My original remark was made not to question your competency, but to simply alert you that your personal thoughts should be more carefully shared. If you share them in a post, it's probably something you'd inadvertently say.

Return to Top
#147046 - 01/09/04 06:36 PM Re: Invalid SSN
Queen Mum Offline
Power Poster
Queen Mum
Joined: Mar 2001
Posts: 3,920
OK
I probably shouldn't respond to you, but you should keep your assumptions to yourself. My family has Hispanic friends, our bank has employed several Hispanics and I have nothing against them any more than anyone else - just a fact that we have a closer proximity to Mexico than New York.

And did I say that we called the Social Security Administration on this one? No. I just commented that we HAD (meaning past) tried and couldn't get anywhere. You are assuming again.

Respond away if you wish, but in the future I think I and all others posting to this thread will probably disregard your comments. END!

Return to Top
#147047 - 01/09/04 07:02 PM Re: Invalid SSN
Anonymous
Unregistered

Quote:

FYI - we have tried calling the Social Security Office for verification and they will not give out information except to the holder of the SSN in question.




Return to Top
#147048 - 01/09/04 07:07 PM Re: Invalid SSN
Anonymous
Unregistered

Obviously, we have an "anon" with too much free time on his hands.

Return to Top
#147049 - 01/09/04 07:17 PM Re: Invalid SSN
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
Quote:

Obviously, we have an "anon" with too much free time on his hands.


The following is meant for the Anon mentioned in the quote not for swamped.

Everbody together now...........

HELLLLLOOOOOOOOOO RAYYYYYYYYY!
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#147050 - 01/09/04 07:45 PM Re: Invalid SSN
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
Well, I hesitate to wade into this mess, but if the original anon's intent was to point out to our friend from Oklahoma the error of her ways (and please note I am not agreeing with anon), then he should have evailed himself of the private message system and not started public attacks.
I don't think the motive was to be helpful, but the modus operandi of the famous unnamed poster from out West that Dan has fingered.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


Return to Top
#147051 - 01/09/04 08:08 PM Re: Invalid SSN
SMQ, CRCM Offline
Power Poster
SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Quote:

Your error in judgement is minor compared to the so-called diamond discussers who offer useless drivel and lament over anonymous postings instead of offering mature, helpful discussions...


Notice R has not offered "mature or helpful discussions" so, ......

Quote:

I have no axe to grind...


(hang on, I had to get up off the floor on this one) Sure sounds like it. (on a pretty regular basis.)

Quote:

There is no industry or regulatory pressure for any FFIEC- or state-supervised institution to extend credit...


FFIEC???

Quote:

You won't concede that your remark was unwarranted, and that it was done for effect to generate more posts...


We know who is trying to generate more posts.

Go ahead, take your best shot. I've been shot down by better (i.e. flood) and I respect their opinions.
_________________________
NOLA is my Beach!

Return to Top
Page 1 of 2 1 2

Moderator:  Andy_Z