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#1405740 - 06/18/10 07:21 PM ITIN Used for ID
ozzie Offline
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Can we use an ITIN as a means of Identification for our CIP. According to IRS a TIN is a SS#, ITIN or EIN. Is this number OK as a means of identification?

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#1405748 - 06/18/10 07:27 PM Re: ITIN Used for ID ozzie
rlcarey Online
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A number is not a form of identification unless combined with some sort of verification and then it would still be consider non-documentary identification.
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#1405753 - 06/18/10 07:29 PM Re: ITIN Used for ID rlcarey
edAudit Offline
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You are here
Agree with rlcarey but would like to add that need to follow the BOD approved policy of your Bank.
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#1405802 - 06/18/10 08:29 PM Re: ITIN Used for ID ozzie
Elwood P. Dowd Offline
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A number is no more a form of identification than a name is.
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#1405808 - 06/18/10 08:34 PM Re: ITIN Used for ID ozzie
ozzie Offline
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I didn't make myself clear on this question. Can the ITIN be used as the Identification Number that is required as one of the 4 items needed to open an account. Can it be used in place of the Soc.Sec Number or EIN?

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#1405822 - 06/18/10 08:42 PM Re: ITIN Used for ID ozzie
Elwood P. Dowd Offline
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Yes, any U.S. issued number will work. Only a non U.S. person will be offering you an ITIN, so your CIP should require evidence of foreign citizenship.
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#1405831 - 06/18/10 08:51 PM Re: ITIN Used for ID Elwood P. Dowd
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Sounds like I'm in the minority here, but I did NOT allow for ITINs to be used for account opening instead of SSN. The way that ITINs are issued does not guarantee legal immigration status.

The program was created for the purpose of tax filing of "passive income", NOT actual salary or hourly income. The use of the ITIN for such income sources is an unintended misuse of it. Receiving an ITIN number does not in any way confer the right to work and receive income in the United States.

Since Federal tax law prohibits the IRS from sharing data with other government agencies, including the Department of Homeland Security, illegal immigrants know that the tax information will be confidential and not be used to deport them.
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#1405839 - 06/18/10 09:03 PM Re: ITIN Used for ID Aggs
Elwood P. Dowd Offline
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Banks are not required to establish immigration status...the customer may not even be in the U.S.

The ITIN is a U.S. issued TIN and is acceptable on the CTR, the DOEP, information returns, etc. When ITIN application rules were revised a few years ago some banks actually became portals for processing W-7's; i.e. ITIN applications and welcomed the ITIN's use at account opening.

Any refusal to accept the ITIN would be acceptable, but it would be based on policy, not law. Just as some banks require an SSN to open an individual account, such a policy would be a subtle, legal act of discrimination against some non U.S. persons.
Last edited by Ken_Pegasus; 06/20/10 11:49 AM. Reason: Initially did not have time to respond in detail
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#1405842 - 06/18/10 09:07 PM Re: ITIN Used for ID Aggs
rlcarey Online
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If the non-US person has an ITIN, it is perfectly acceptable to use it to meet the 4th information requirement. Meeting the four CIP information requirements has nothing to do with customer verification. How you meet customer verification requirements is totally up to the Bank and the individual Bank's CIP policy.

(4) Identification number, which shall be:

(i) For a U.S. person, a taxpayer identification number; or

(ii) For a non-U.S. person, one or more of the following: a taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.
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#1405949 - 06/21/10 12:08 PM Re: ITIN Used for ID rlcarey
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Right. I agree with both posts above (Ken and Randy) and it definitely was our internal CIP policy not to accept those. We'd gotten burned in the past and so we stopped accepting them.
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