BSA TIN Requirement & Religious Beliefs

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Question:

Regarding the TIN requirement of BSA 31 CFR 130.34, does it apply to the members of religious groups who do not have SSNs or TINs due to their beliefs? If they want to open an account, are they required to furnish a TIN? What if they don't have a TIN and they are an existing customer?

Answer:

There are no exceptions for CIP's requirements to obtain information. After October 1, you are required to obtain a SSN from an individual opening an account regardless of their religious beliefs. In effect, they will not get the SSN and you will refuse to open the account. It's a stupid result, but you cannot avoid it.

As for a customer with an existing account, you will not be required to obtain a TIN for that account CIP only applies when a new account is opened.

Your bank may design an exemption for customers with existing accounts who are opening new accounts as long as you are certain of their identity. Your wording of the exemption would determine whether you were required to obtain a SSN from a customer with an existing account who had not given you a SSN previously.

First published on BankersOnline.com 07/07/03