Is it possible to report foreign borrowers to credit bureaus without a TIN?

Report the Social Security Number (SSN) of the primary consumer. Report only valid U.S.-issued SSNs.

Reporting of this information is required as the Social Security Number greatly enhances accuracy in matching to the correct consumer.

If the consumer does not have a SSN or one is not available for reporting, zero- or 9-fill all positions.

Notes:

If the Social Security Number is not reported, the Date of Birth is required to be reported.

Do not report Individual Tax Identification Numbers (ITINs) in this field. ITINs do not prove identity outside the tax system and should not be offered or accepted as identification for non-tax purposes, per the Social Security Administration.

Do not report Credit Profile Numbers (CPNs) in this field. The CPN should not be used for credit reporting purposes and does not replace the Social Security Number.

So we can report them but we should not report a ITIN in place of a SSN?

Above is what the Metro 2 guide indicates. Call your CRA representative if you have further questions. You might also want to request a copy of the guide.