Question - IRSN

We have an applicant (a US born citizen) who does not have a SSN on the basis of religious reasons. He is adamant that he be allowed to use an IRSN in lieu of the SSN. He's also adamant that he should not have to apply for a SSN and then file IRS form 4029 to be exempted from participating in the social security system, again for religious reasons.

I have researched the IRSN and discovered that it is an Internal Revenue Service Number. It's a temporary number that is used by the IRS on tax returns without a valid TIN. When issued, the IRS also mails a form W-7 with instructions to file an application for a TIN.

Naturally, my CIP doesn't even consider the IRSN. I don't think it should.

However, I want to be open minded and fair. Does anyone here have experience with the IRSN? Are they really "just as good" as a SSN?

I appreciate any and all feedback.

For consumers, we accept a SSN, ITIN, foreign passport and jurisdiction of issuance. We generally don't make exceptions unless there is a really sound business reason.

Having an account at your bank is a privilege and not a right. He plays by your rules or he finds a new bank. If he has never been issued a SSN in his lifetime, then he should know how this works. He sounds like a crackpot.

What does he mean by " he should not have to apply for a SSN and then file IRS form 4029 to be exempted from participating in the social security system, again" - that is a one time process

"Having an account at your bank is a privilege and not a right. He plays by your rules or he finds a new bank. If he has never been issued a SSN in his lifetime, then he should know how this works. He sounds like a crackpot."

This

Thank you, Randy.

He states that even having the SSN violates his religious beliefs.

The only reason I am concerned is that he is interested in credit. I don't want to get into a fair lending boondoggle where he claims disparate impact. I think we win, but the reputation risk and other issues weigh on my mind.

I am not sure how, if you cannot get what you need in order to perform CIP under the regulations, you are discriminating against him.

(4) Identification number, which shall be:

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

I would say thanks but no thanks

I think the need to conduct a CIP and comply with KYC requirements would suffice as a legitimate, nondiscriminatory business purpose.

From my years of experience, a potential customer that gives you trouble prior to opening will only get worse after you onboard him/her.

Amen! (It's the whole "No good deed goes unpunished" theory.)

Is this person Amish or Mennonite? I have not heard of any other religious exemptions for SSN.

I read in another forum specifically about Amish. Went there and looked it up. One responder had a large Amish Mennonite community and stated probably 80% do not have a SSN. They had this written into their CIP policy, however they still required two forms of identification.

Another person stated they require an SSN for anyone from their Amish community to have an account. No exceptions.

I'm guessing this is not your issue or you would have seen it before. Sounds like this person is just being a weasel.

We have a small handful of Amish accountholders. Initially they had not provided SSN as they stated that they did not have them. We instructed them that in order to do banking with us, they needs to obtain a SSN, and also told them to inquire at the Social Security Administration regarding Form 4029. We only had a couple of accountholders leave the bank.

I'm also in Kentucky, and we had this same issue come up with certain Amish customers in one location a couple of years ago. While doing a review, we found that a few accounts had been opened with an IRSN instead of a SSN. We had to research this extensively, even asking the FDIC and a compliance consultant. Neither had ever heard of this problem, and did not have any clear guidance on what we should do.

Because it seems clear that the IRSN was not intended to be used as an SSN, and the account is for a U.S. individual, we decided to no longer accept any future customers using the IRSN. But we elected not to close the few accounts we had already opened, since the experts we consulted did not advise that closing those accounts was required.