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 matrÃcula 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.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com