Banks routinely spend considerable time in researching IRS B Notices where depositors have failed to provide a TIN, either a SSN or EIN. It is not unusual for a bank our size to have thousands of missing TINs. There are also IRS monetary penalties for a bank that has missing TINs.
Do any of your banks assesse a fee on depositors for failure to provide a valid TIN? For instance, if a TIN is not provided within 90 days of account opening a fee of $100 plus any IRS penalties paid would be assessed annually until the TIN is provided.