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Non-resident Alien - CIP Documentation

Question: 
We have a customer who has documentation to support that he is a non-resident alien, however he meets the substantial presence test and has a "For work purpose only" social security card. Would this customer be considered a resident or non-resident alien for bank purposes, and can we use the social security card for CIP documentation?
Answer: 

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: 

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

First published on 11/30/2009

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