Good afternoon,

We are starting to see an increase in loan requests being made for NRA's and also Canadian citizens. In our CIP policy at least one form or US ID is required whether it be an ITIN, US Visa, or Driver's license as well as Passport and ID from country of issuance. OFAC and ID verification are ran as well as their name being ran through world check. Because we have an exam coming in the next year and we are just starting to handle these types of accounts I want to make sure we are collecting as much as possible on these potential customers and was hoping to find out how other banks and BSA officers handle identifying these types of customers if they do in fact bank them. Thank you.

We bank a lot of NRAs and actively lend to those who qualify. On the BSA side, we require a valid passport as a primary ID and a second non-documentary form of ID as well. They must pass through sanctions screening as well.

The only forms of TINs we will accept are SSN, ITIN or a foreign passport and jurisdiction of issuance.

I worked at a very small bank for years and have had no exposure to NRAs until now. For CIP purposes, am I correct in thinking that for an NRA we can either use an ITIN or another ID number, such as a passport number? The ITIN would be required for an interest-bearing account, but not necessarily for CIP.

For a non U.S. person, the "identifying number" can be either a U.S. TIN or a number provided by the country of origin with a satisfactory description; e.g. a passport number. If you also receive a U.S. TIN you would use it for information reporting.

Do what ACB does...

Thank you!

if they individual has a SSN and state issued ID, how do I know they are a non-US person?

You ask them.

For any individual, "Citizenship?" is the first due diligence question.

What about a Resident Alien?

CSR opened an account yesterday and the RA had his passport, visa, driver's license but no green card (perm residency card). While becoming a resident alien, his lawyer told him his VISA was suffice documentation, he didn't need a green card. It was my understanding that you need the green card to work in the US? He has a business with his brother. The CSR opened a business account for them but for the customer he also opened a personal account and requested a credit card. They gave it to him.

So to clarify, is a green card (perm residency card) required to work in the US?

You do not need a green card to work in the US. You need a work visa. Lots of people work in the US legally without green cards.

What sort of visa?

You do not need a green card to work in the U.S., but you do need DHS permission. Too much here to fix...suggest you call the customer back in and start over. (Disregard anything his lawyer said or is purported to have said: Never take advice from the other guy's lawyer.)

(Disregard anything his lawyer said or is purported to have said: Never take advice from the other guy's lawyer.)

Best advice ever!!!

so, every deposit and loan application should ask, "Are you a U.S. Citizen? yes or no"

Well, using applications is one way to gather this information.

I suggest you ask them for the name of the country where they are a citizen, not just whether or not they are a U.S. citizen. (Ask one question instead of two.)

we still use paper apps on both sides. Without putting it on the app, how do we bring that up in conversation?

You ask them when you ask them to show you identification documents for CIP. I'm sure you have a CIP checklist. After all, isn't that what we are talking about.