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#1583718 - 07/27/11 03:16 PM ITIN
ledfoot Offline
Member
Joined: May 2004
Posts: 93
Georgia
Realize this is an old question but still unclear whether or not an ITIN is acceptable for CIP. Can a bank decide to accept it, if additional ID verification is complete (i.e. Valid DL, passport etc.)? Under CIP rules opening account without a SSN or TIN is not permitted. So if a new account is opened with just an ITIN is that a violation?
We do have some accounts with ITIN's only and BSA examiners get a list of those when we're examined but have never been sited with a violation.
Last edited by ledfoot; 07/27/11 03:27 PM.
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#1583921 - 07/27/11 06:30 PM Re: ITIN ledfoot
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
The regs say that you need a US Identifying number for a US person.
For a Non US person, it could be an ITIN, a passport or an alien ID card.
But your bank has to state in their policy what they will accept for the two groups: US person and Non US person.

Hope this helps clarify it.

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#1585522 - 07/29/11 08:57 PM Re: ITIN MagicCity
ledfoot Offline
Member
Joined: May 2004
Posts: 93
Georgia
Ok, that's what I thought but somebody said something the other day that made me wonder if all this time, I had misunderstood.
Thanks
_________________________
Ledfoot

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#1585601 - 07/29/11 11:02 PM Re: ITIN ledfoot
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I would add that most banks that I know of, require a valid passport as the primary ID for a Non US Person; anything else would be Secondary ID.

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