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#2169021 - 03/19/18 07:22 PM Social Security Card
Compliance Action Subscriber 1226 Online
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Is a bank required to make a copy of a social security card when opening an account for a new customer, for BSA/AML purposes?
Or can the bank just verify the SS# and write it down?

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#2169024 - 03/19/18 07:26 PM Re: Social Security Card Compliance Action Subscriber 1226
BrianC Online
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The USA PATRIOT Act does not require that the bank keep copies of any documents. A description of the documents reviewed is sufficient. Note that if the board approved procedures require that the bank keep a copy, then you must follow your procedures.

The bank must also keep a description of the following for five years after the record was made:

•Any document that was relied on to verify identity, noting the type of document, the identification number, the place of issuance, and, if any, the date of issuance and expiration date.
•The method and the results of any measures undertaken to verify identity.
•The results of any substantive discrepancy discovered when verifying identity.
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#2169025 - 03/19/18 07:26 PM Re: Social Security Card Compliance Action Subscriber 1226
Sunshine Lady Offline
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Banks are not required to make a copy of a social security card, we just have to verify the number and we put it in our core system.
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#2169069 - 03/19/18 09:53 PM Re: Social Security Card Compliance Action Subscriber 1226
RockChucker, CAMS Offline
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The Country
We don't even look at the card, we use a system that verifies the SSN the customer gives us to the name and DOB of the customer to make sure it matches.
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#2169072 - 03/19/18 10:00 PM Re: Social Security Card RockChucker, CAMS
rlcarey Online
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rlcarey
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Galveston, TX
Originally Posted By RockChucker, CAMS
We don't even look at the card, we use a system that verifies the SSN the customer gives us to the name and DOB of the customer to make sure it matches.


Well, the only real way to verify a SSN matches a name is though the IRS and you are only allowed to use that system on accounts in which you have IRS reporting responsibility. That is not your entire universe of accounts. Any other system will only tell you if that SSN has been reported as used with that name and birth before by another reporter. So it is not verification.
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#2169154 - 03/20/18 03:28 PM Re: Social Security Card Compliance Action Subscriber 1226
RockChucker, CAMS Offline
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The Country
While that is true all we are required to do is have a program that allows the bank to form a reasonable belief that it knows the true identity of each customer.
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#2169357 - 03/21/18 02:49 PM Re: Social Security Card Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Online
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Thank you for the responses, we got written up for not retaining a copy of a Social Security Card

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#2169372 - 03/21/18 03:30 PM Re: Social Security Card Compliance Action Subscriber 1226
rlcarey Online
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rlcarey
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Galveston, TX
Written up by whom? That is pretty silly - a SSN is not an identification document. In fact it used to have a legend to that fact a few years ago. It would only be a problem if your CIP specifically called for obtaining a copy as the regulations do not require you to maintain copies of any ID document..
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#2169373 - 03/21/18 03:31 PM Re: Social Security Card Compliance Action Subscriber 1226
bcompliance Offline
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Was that a requirement in your BSA policy?
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