The standard TIN Exception report from our processor picks up non resident alien coded accounts because the number field is empty. The "type" field is "A" for non resident alien. We use FIS's Bankway System. The examiners have questioned us about this because they like to see empty TIN Exception Reports, so we are considering putting a generic number (999-99-9999) in the number field so that these accounts are not picked up as exceptions. Does anyone else have this problem and are there any hazards for us to consider if we do this?

We have a different code for this field which denotes NRA and enter the passport in the field, which is the identifying number that we get for CIP puroses.

Is there some other method that you can use to determine if a NRA was opened?

I would also check with FIS and ask how other banks are dealing with this.

I as an auditor would have no issue with the report as is.

We use 999-99-9999 for NRAs.

How about running the report and excluding individuals that are coded as an alien? Then you will not have any exceptions, except for any holdovers from prior to 2003?? Otherwise, if an examiner can't figure this out, then they need to go back to school.

Also, everyone is going to have to re-think and re-do all of the fake taxpayer IDs they have entered into their systems. When you produce the required IRS 1042-S information reporting forms for these individual at year end you are going to have nothing but troubles.

Our Missing TIN Report filters out customers with a W-8 BEN status. Using all "9"s might also present a problem if your CTR/SAR applications automatically populate the invalid SSN's into the software - you will have to ensure it's deleted each time you file a CTR/SAR.

Thanks for all the good info, especially rlcarey because we did decide to build a custom report. I hate having to spoon feed the examiners but ultimatly it just makes life easier!

Ditto. It was a lousy idea to begin with and it gets worse all the time...