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#799211 - 08/21/07 02:49 PM Social Security Card & CIP
TDM Offline
Member
Joined: Nov 2005
Posts: 82
I'm sorry, this has probably been addressed before, but...

Would it be actual regulation that, for example, to verify a social security number a bank requests to see the social security card or would it be a best practice?

As I understand it, by law, we are required to obtain a tax id number... but, by law, do we have to verify it?

I have someone telling me that as long as a customer gives us their tax id and verifies it by signing a signature card or a w-9, that's all, by law, that's required.

I'd appreciate help.

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BSA/AML/CIP/OFAC Forum
#799219 - 08/21/07 02:58 PM Re: Social Security Card & CIP TDM
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
You do verify it.
Your ChekSystems service will verify the SSN.

However, if you are taking it as a 2nd ID - you need to have a copy of the card in your file (if that is what your CIP states with regard to IDs.)

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#799228 - 08/21/07 03:03 PM Re: Social Security Card & CIP MagicCity
TDM Offline
Member
Joined: Nov 2005
Posts: 82
We're a pretty small bank... we don't, presently, use ChekSystems.

Reading through our CIP "policy," I don't specifically see anything saying we require something to verify the SS#... yet, of course, it is required that we get a SS#.

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#799374 - 08/21/07 04:35 PM Re: Social Security Card & CIP TDM
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Your CIP Identification requirements are risk based and have to be spelled out in your bank risk assessment and your written policy. (Two separate documents).

You do not have to verify the SSN given to you, - that is not required.

What the regulation requires is that you have a reasonable belief that you know the true identity of your customer.

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#799452 - 08/21/07 05:27 PM Re: Social Security Card & CIP MagicCity
Bagweaver Offline
Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
We're a small bank and don't use Chex Systems either. However, we do pull a credit report and verify the SS# that way.

Neither our outside BSA auditor and our regulator had a problem with it.
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#799512 - 08/21/07 06:00 PM Re: Social Security Card & CIP Bagweaver
LaNae Offline
Junior Member
Joined: Apr 2002
Posts: 36
Upper Midwest
I would hesitate to require customers to show a copy of their Social Security Card. Consumers have been instructed for the past few years to not carry their SSN card with them, but rather to keep the card in a safe place. Asking the consumer to bring the card for you to verify may not be received well especially if the customer is in front of you to open the account and then they have to drive home to get the card.

Just food for thought.

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#799533 - 08/21/07 06:12 PM Re: Social Security Card & CIP LaNae
TDM Offline
Member
Joined: Nov 2005
Posts: 82
I'm just struggling with what is required by the regulations.

Four pieces of information are required to be obtained prior to opening an account... three of those can be *verified* by a valid driver's license.

We're probably not going to be doing a whole lot more than we're required to do because we're a very small, very low risk bank. So I'm just trying to figure out for sure whether verifying a tax id #, in some manner, is required or just a best practice.

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#799547 - 08/21/07 06:19 PM Re: Social Security Card & CIP LaNae
NewTooBSA Offline
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
The social security card is only as legitimate as the person presenting it to you. Personally I feel that using ChexSystems or a credit bureau would be a better method of verifying a social security number than looking at a card.

Just remember, whatever your policy states you will do is what you are required to do.

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#799585 - 08/21/07 06:47 PM Re: Social Security Card & CIP TDM
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Originally Posted By: TDM
I'm just struggling with what is required by the regulations.


The regulation requires that you obtain 4 pieces of information:
Name
Address
DOB
US Identifying Number.

After that the regulation says that you must have "a reasonable belief that you know the true identity of your customer."

What steps you take to verify the information given to you, or what additional information you choose to request - is your choice, based on the risk your bank wants to take.

Whatever you decide, you must have it in your Risk Assessment and BSA Policy.

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#799763 - 08/21/07 09:13 PM Re: Social Security Card & CIP TDM
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Magic City knows her stuff. From the supplementary information accompanying the final CIP regulation:

Treasury and the Agencies recognize that there currently is no method that would permit a bank to verify, for example, a taxpayer identification, passport or alien identification number through an official source. Accordingly, the final rule provides that a bank’s CIP must contain procedures for verifying the identity of the customer, "using theinformation obtained in accordance with paragraph (b)(2)(i)," namely, the identifying information obtained by the bank. Thus, a bank need not establish the accuracy of every element of identifying information obtained but must do so for enough information to form a reasonable belief it knows the true identity of the customer.

The opening statement is no longer correct - you can verify name TIN combinations via IRS E Services. However, you are not required to verify all four pieces of required information, only enough to allow you to establish a reasonable belief of the person's identity.
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