Good afternoon,

Does anyone NOT take ITIN's when opening bank accounts? We are considering no longer opening accounts for customer's with ITIN's but want to know if this could lead to issues that we don't want to have. Could this be a UDAAP issue or something to do with discrimination?....if you do take ITIN's, do you restrict if they only have a green card or do you require them to show their VISA?

We are thinking of the risk impact it could present to the bank if we continue to take ITIN's if the person does not have their green card and the person has to leave the country and the bank get stuck with a loan....

Open only non-interest bearing accounts, then you eliminate the need altogether. What else you do from a CIP standpoint is another matter.

Thanks for the info. I would like to see what other banks are obtaining for identification documentation for customer's with ITIN's....

Well an ITIN, just like a SSN is not identification. If you are talking about foreign nationals, then in the banks I used to work for, a passport was always required - end of story - and with the banks that I consulted for on the southern border, many also excepted a matrícula consular card. Some banks went further to determine that the person was still legally in the US by reviewing a Visa, if required, but that really goes beyond CIP.