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#2091991 - 08/05/16 07:17 PM Re: Resident and Non-Resident Aliens rlcarey
*W*W* Offline
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If an individual is a citizen of the US, what difference does it make when he got his SSN??? Maybe he didn't need one until he was 21 years old. Again, how do you know when it was issued?? It could have been yesterday.

Our debit bureau and other reports we pull tell us when the SSN was available for issuance. Other times the report tells us the SSN was issued to a permanent resident immigrant. Our CIP requires us to obtain certain additional documents if the person is permanent resident or NRA. In the example I provided earlier, to me the SSN issuance would be an indicator we may have a permanent resident or non-resident alien, thus triggering our additional documentation requirements.

As I'm typing this I'm thinking it's a matter of our CSRs asking the relevant questions (country of origin, resident status) when we have a situation like this.
Last edited by *W*W*; 08/05/16 07:19 PM. Reason: omitted wording
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#2092001 - 08/05/16 07:41 PM Re: Resident and Non-Resident Aliens TheLoanRanger
rlcarey Offline
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Our debit bureau and other reports we pull tell us when the SSN was available for issuance.

What are they basing that on - the SSA has gone to a random issue of numbers and there is no longer a way to tell when a number was issued that I am aware of.
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#2092003 - 08/05/16 07:45 PM Re: Resident and Non-Resident Aliens TheLoanRanger
edAudit Offline
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The SSN number could have also been issue while the customer was in the US at a prior time with a different visa classification that required a SSN (rare but possible)
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#2092005 - 08/05/16 07:49 PM Re: Resident and Non-Resident Aliens TheLoanRanger
*W*W* Offline
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The SSNs I'm looking at were available for issuance prior to the SSN randomization. At any rate, I think we need to go back to the applicant and verify residency status to ensure we've complied with our CIP policy.
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#2092072 - 08/08/16 11:57 AM Re: Resident and Non-Resident Aliens rlcarey
Elwood P. Dowd Offline
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Quote:
the SSA has gone to a random issue of numbers and there is no longer a way to tell when a number was issued


To illustrate, according to the old SSA charts, an SSN that begins with 305-56 was issued in Indiana in 1966. However, another SSN with the same first 5 digits could have been issued last week in Arizona.
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#2092193 - 08/08/16 06:22 PM Re: Resident and Non-Resident Aliens TheLoanRanger
StevenD Offline
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The ITIN expiration document from the IRS (Notice 2016-48) states that banks will not be penalized for information reporting that includes an expired ITIN. You will find this paragraph near the end of the document.

USE OF AN ITIN SOLELY ON AN INFORMATION RETURN
An individual whose expired ITIN is used only on information returns filed and furnished by third parties, such as Forms 1099, is not required to renew the ITIN. ITINs may continue to be used for information return purposes regardless of whether they have expired for individual income tax return filing purposes. If the individual is later required to file a tax return, however, the individual’s ITIN will have to be renewed at that time. Additionally, the third parties who file and furnish information returns with an expired payee ITIN will not be subject to information return penalties under sections 6721 or 6722 solely because the ITIN is expired.

As Ken said, "It is not your problem."
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#2163102 - 02/05/18 03:34 PM Re: Resident and Non-Resident Aliens TheLoanRanger
morirse de risa Offline
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Does anyone have any procedures or policy regarding resident aliens or non-resident aliens that they would be willing to share?

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#2163202 - 02/06/18 10:58 AM Re: Resident and Non-Resident Aliens morirse de risa
Elwood P. Dowd Offline
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Seriously, my policy would not go beyond "No U.S. TIN, no account. If you give me an SSN or an ITIN I'll give you an account and a hug!"

Simultaneously applying BSA's and the Internal Revenue Code's TIN requirements is like playing three dimensional chess. Doing it right is going to cost your bank more money than it makes off these relationships unless they are truly a significant part of your customer base.
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#2170075 - 03/26/18 04:27 PM Re: Resident and Non-Resident Aliens TheLoanRanger
Susielou Offline
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On our BSA /AML/CIP Risk Assessment there has been a statement of how many of our customers are not US citizens. We have very few. We moved to a new database that doesn't give that information. Should I be tracking this information?

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#2170076 - 03/26/18 04:30 PM Re: Resident and Non-Resident Aliens TheLoanRanger
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We do, both in core and our automated AML system. It comes up often.

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#2170140 - 03/26/18 07:04 PM Re: Resident and Non-Resident Aliens Susielou
Elwood P. Dowd Offline
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Citizenship? is the "fifth question" banks must ask individual customers, right after name, address, identifying number and DOB. There is no point in asking if you cannot keep track of the response.

Honestly, I cannot imagine your software does not record the information. Contact the vendor to be certain...
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#2170355 - 03/27/18 04:55 PM Re: Resident and Non-Resident Aliens TheLoanRanger
Sherlocked Offline
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Code the ones from your old database, then I guess you could pull a report (by ID maybe?) from your core to be able to code the customers who are not US citizens. We use a specific BSA risk code for ours.
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