Answer by Randy Carey:The substantial presence test only impacts whether or not a W-9 or a W-8BEN is completed. The bank can treat him any way they choose, but IRS information reporting would be based on the W9 or W-8 reporting rules. Whether you can use an SS card for CIP identification purposes would be solely based on your board approved CIP program. In my opinion, a SS card is not identification because it has no picture.
Answer by Kathleen Blanchard:A social security card is generally used only as supporting CIP documentation, to resolve a name discrepancy, for example.
First published on BankersOnline.com 11/30/09