When opening a new account for a new customer, with regards to the Patriot Act,is the bank required to see the actual social security card or another legal document with the SS number on it for verification in order to be in compliance. WE do require other forms of ID and also use CHEXSYSTEMS.

You are not requiered to see the card, just to obtain the number.

Your risk based cip will define what documents you will rely on to verify customer id. If you determine this to be the original ss card, then you would have to require it. Otherwise, you will obtain the number but not necessarily have to validate or authenticate it. Since many states no longer include the ssn on drivers' licenses, you may not be able to verify it on site--at time of account opening. Lexus Nexus and the like may be employed to verify and or authenticate based on matches of ssn/name/address/etc. again, as your risk based cip dictates.

I have my original SSAN card. It was issued long ago. I was maybe 10 when I got it. I do not normally carry it in my wallet. Perhaps that is why I still have it.

I wouldn't expect to have to get it to open a new account. As I recall it is also pretty plain and would be easy to reproduce with a home PC. The signature looks nothing like mine does today. My opinion is that it would serve little purpose other than to put a check mark next to
__Saw 2nd ID form.

If much credibility was put into this, it certainly would be a risk-based procedure.

In addition to the online providers mentioned above, the WatchDOG SSN software can also verify a social security number but without incurring any online transaction charges.

But none of the software solutions on verifying SSN will do anything more than verify that the number has been issued and may belong to the person who gave it to you. The only verifyer of SSNs and EINs that will match names and numbers is the U.S. Government (SSA and/or IRS), and their program is still, I believe, in testing.

There's another good discussion in the PA section that is closely related.

http://www.bankersonline.com/ubbthreads/showthreaded.php?Cat=&Board=Penn&Number=78191&page=0&view=collapsed&sb=5&o=&vc=1

I'm hopefull that ss# will drop off the list of 'required' things to provide. It's really not a valid form of identification. If we 'must' have an ID# of some sort we'd be far better off with D/L, Non-Driver ID or a passport # - you know... the same sort of thing we need for "non-U.S. Persons."

I just don't like the idea that I'm going to be treated with greater scrutiny as an American than I would be if I were from 'some other' place.

As an afterthought to my previous posting, here's something that we should not forget about.

The nineteen September 11th hijackers opened 35 bank accounts using bogus social security numbers, as reported in this New York Times article. Verifying the SSN would have alerted bank officials. Requesting the SSN should never be dropped from the 326 requirements.

Before the September 11th tragedy, the industry offered very few SSN software solutions that were affordable or easy to implement. Things have changed. Here's what you should expect from an SSN software solution that performs a "Level 1" baseline verification:

1. Determines if the SSN is a valid number that has been issued by SSA;
2. Verifies whether the customer's age is logically consistent with the SSN issue date;
3. Reports the State and Year when the SSN was issued;
4. Verifies whether the SSN is a stolen number that belongs to a deceased person;
5. Stores customer's name and verification results for recordkeeping and compliance reporting purposes;
6. Provides customer disclosure notice;
7. Verifies single SSN or entire customer database in batch-mode.
8. No per record charges, except for a license fee.

If the Level 1 SSN verification raises a red flag, then you may want to consider using an online ID verification service. You will incur a per record transaction charge ranging from $1 to $5, including a one-time set-up fee, depending on the vendor you choose.

The Level 2 verification will take the SSN verification one step further by comparing the customer's SSN to a credit header file. Specifically, it determines if the customer's SSN, including name and address, matches the credit header record information. Phone, address, high risk phone/address, driver license (for certain states), DOB, fraud score and other logical, negative and positive verification methods are also performed.

Level 2 is the most comprehensive approach to ID verification but it should only be used when the risks justify the per record costs. Level 1 allows you to perform a baseline verification for all new and existing customers without incurring any per record charges, without leaving a footprint on a credit record, and without offending any long-term customers.

I beg to differ that it should never be dropped. The fact is that you don't need one if you are a 'Non-U.S. Person'. Which means the net effect of the law from this regard is that we 'U.S. Persons' are treated with greater scrutiny than if we were "non-U.S. Persons". Doesn't feel right to me... (Amendment XIV perhaps?)

Everyone likes to through the terrorist using ssn's around but the fact is that we've got huge identity theft problems and giving the 'bad guys' another reason to want your ss# doesn't seem like a very good idea.

Besides as I've said elsewhere (or maybe here) working around this is easy anyway which means that only the 'good guys' (being the people and the banks) are left holding the bag on implementing something with no residual value.

ok.. so that was my 2 cents (maybe even 3 cents).

As mentioned, SSA and IRS are working on a TIN verification service that is based on primary rather than secondary sources. Hopefully, it will be operational by 10/1/03. Presumably, it will be free.

Otherwise, as JacFSB said, the information requirements of CIP require you to get the number and the verification requirements would allow you to accept the card as a form of verification.

As Andy notes, a SS card is no better than "secondary" ID, but I have to admit I would attach some credibility to Andy's dog eared document. That is partially due to an anecdote I heard from an Oklahoma banker this week whose prospective customer had produced a new SS card with a number that was an "impossibility" according to SSA publications. She handed the card back to him and said they could not open the account. He then pulled out a second card in equally pristine condition and said, "Here, try this one. I bought two."

Lawrence's comments relative to ID on citizens vs. non citizens hit a nerve. The following is from my comment letter on the proposed regulations:

It is worth noting that the USA PATRIOT Act was prompted by the actions of foreign, not domestic, terrorists. Nevertheless, this proposal does nothing to require or facilitate better identification of nonresident aliens - BSA regulations already require banks to obtain evidence of foreign citizenship and record the information. It is Kafkaesque that our country's attempt to keep international terrorists out of the banking system is entirely focused on getting better identification from U.S. citizens.