CTR returned for SSN

Posted By: P*Q

CTR returned for SSN - 10/23/08 07:20 PM

We had 2 CTR's returned for TIN no matching name. This customer has been banking here forever and it's their SSN! She does not have her social security card however, I was going to copy that and return it with the CTR. Any other thoughts? Can I just write a note that it is indeed their SSN.
Posted By: Skittles

Re: CTR returned for SSN - 10/23/08 07:23 PM

Is her name spelled out correctly? Can you get a tax return to verify? Other than that, just write on there that you verified the number with your records.
Posted By: ktac MITCH

Re: CTR returned for SSN - 10/23/08 07:26 PM

I am with Skittles,
Just be diligent to confirm that the number you have is what the customer provided - check against their Tax Return / make sure you didn't transpose / etc.
We get these from time to time so they are not uncommon (maybe error at IRS Computing Center )
Posted By: P*Q

Re: CTR returned for SSN - 10/23/08 07:39 PM

We did verify against our records and a loan application where the customer completed the form and signed TIN certification and the number matches our records and the CTR. Strange...
Posted By: Anonymous

Re: CTR returned for SSN - 10/23/08 07:51 PM

Those little indians were having a hard time that day!
Posted By: John Burnett

Re: CTR returned for SSN - 10/23/08 08:57 PM

One possibility is that this lady hasn't always had the same last name, and she has not yet updated her record with SSA. If that's the case, you will get a no-match.

If the problem persists, you can ask her assistance in obtaining a certification of her SSN from SSA. That will reveal any disconnect between SSA's records and yours as to number and/or name.
Posted By: Maytagman

Re: CTR returned for SSN - 10/24/08 06:11 PM

Just my two cents, but, in e-filing we call these "Error Acknolwedgments." The e-filing FAQ puts it simply and best: Verify that the CTR filed matches the BANK'S RECORDS. If it does, take no action. I discourage people from telling customers what forms the customer has to file with the federal government, and from wasting the FI's on-the-clock time tracking and pursuing these non-issues. A tiny fine might apply if you file interest forms on her to the IRS, but if she is in a non-interest bearing account, who cares what the SSA has on file?
Posted By: Princess Leia

Re: CTR returned for SSN - 10/25/08 02:09 AM

PQ, we receive these back now & then too. We write a letter to the IRS explaining that the SSN was correct at the time the account was opened per our CIP (we know because we have a bureau match).

We've never heard back, but kept the correspondence and our response in a separate file just for the examiners
Posted By: Elwood P. Dowd

Re: CTR returned for SSN - 10/26/08 02:23 PM

The letters I have seen do not request a response and the IRS only expects a response if you can give them a different number. (Sometimes field examiners think they know better and say you should have responded with a non-answer answer.)

In addition to John's suggestion for a possible error, compare the number given on the letter to the number you actually used on the CTR. If you file on paper, your CTR information was transcribed by a government contractor and "#/*~ happens."
Posted By: Anonymous

Re: CTR returned for SSN - 10/27/08 05:01 AM

John and Ken have very good advice...!

We have had a bunch of these. Generally, it is the "last name change" due to marriage or divorce and the customer made no change at SSA, etc...
However, be mindful that you do your due diligence.
We did find one (1) customer that had an account with the bank for 23 years and "our" records were wrong.
We found out that for all those years we had the wrong TIN... Ooops!
Posted By: Maytagman

Re: CTR returned for SSN - 10/27/08 06:18 PM

Originally Posted By: Princess Leia
We write a letter to the IRS explaining that the SSN was correct at the time the account was opened per our CIP (we know because we have a bureau match).
We've never heard back, but kept the correspondence and our response in a separate file just for the examiners


I suggest calling the IRS BSA line and asking them if they want you to mail them a letter. They haven't responded for a reason. Meanwhile, sensitive customer data is in the mail, and some considerable time and expense are achieving nothing of value. IMO, I would think a copy of the bank's records stapled to your as-is CTR would be the same or better than a copy of a letter to the IRS.
Posted By: Princess Leia

Re: CTR returned for SSN - 10/28/08 01:22 AM

While I agree with what you suggest, our examiners have requested (in the past) all corresepondence with the IRS and have expected us to have responses back. Additionally, we are following internal counsel's advice.
Posted By: Kathleen O. Blanchard

Re: CTR returned for SSN - 10/28/08 04:15 AM

Originally Posted By: Maytagman
[quote=Princess Leia]They haven't responded for a reason.


The IRS is incredibly behind on these manual filings. I am always amazed when I audit banks and see how old some of these letters are. But the regulators want to see that the bank responded. I have seen gaps up to 12 months between initial filing and an IRS request for correction, that another gap on the response. It's amazing.