Fudging TINs

Our system wants a TIN for every name line ... even if it's just a nickname such as: "House Account".

To combat this issue - my new accounts have been using TINs like 999-99-9999 and 888-88-8888. Is this OK?

I'm thinking No ... but in order to change the process, I'm sure I'll need some sort of Guidance to direct them to.

Anyone else have a similar situation?

Sounds like purely a systems limitation and how you handle it is up to you. Your decisions may impact other processes, like certain report generations.

They are using the same numbering system for Foreign Customers without TINs ... It is creating quite the report when trying to figure out who is Foreign and who is just an extra name line.

I would raise the issue with your system's provider. They could be able to either make the the field optional for secondary titling positions or allow a blank entry. Can you make designations like "house account" an address line instead of a name line?

If your vendor doesn't listen to your pleas to allow for a blank TIN, you could set up procedures outlining exactly what number to use for each situation. For example 999-99-9999 would be a foreign national, 888-88-8888 would be a "House Account" or the like, and so on. That way you can run reports on just those TINs and figure out what is what. Might take a little bit of investment upfront to do maintenance on the existing CIFs, but it could yield nice benefits down the road.

Just make sure that whatever numbers you end up using for these various categories are never going to be used as real TINs.

If the "house accounts" are the bank's own accounts, use the bank's TIN. Many banks do that.

Your system should allow you to point to the TIN that should be used for reporting information to the IRS. The point I'm trying to make is that every name line may not require a TIN. Secondly, you should check to see if your system offers a "title" line that can be used in these situations. Best thing to do is call your service provider. They have undoubtedly had this question before.

This is what we have in place. I now have a listing to what all the numbers mean & review them every month to verify they are being used correctly.

Thank you everyone.