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#147028 - 01/08/04 04:32 PM
Re: Invalid SSN
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Anonymous
Unregistered
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Having worked in SW kansas for several years, we saw our share of forged SSN cards. It was very commonplace. Our policy was we did not process accounts on anyone that had a hawk alert indicating the SSN was not valid. Our main concern being if in fact this individual was other then a united states citizen and the loan went into default, we had no recourse in mexico, (which is where most of them fled when the loan went bad).
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#147030 - 01/08/04 04:59 PM
Re: Invalid SSN
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Anonymous
Unregistered
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What do you mean by the remark, "Oh, the customer was definitely Hispanic." I'm trying to understand this significance to your issue -- which was the need to dig deeper to validate the Social Security number.
While anyone would concede that Hispanic surnames (primarily indigenous to Mexico and Colombia) are disproportionately represented in OFAC/PATRIOT listings, the borrower's ethnicity was not relevant here. Anyone dealing with Social Security numbers knows that there are many duplicate numbers, re-issue errors, and other factors; and the best way for you to easily and quickly cure the identifier question would be to have the borrower/customer bring you various source documents showing that same Social Security number. A consumer who is viably employed will, and should, have a valid SS# with their employer, and that number can be verified; the consumer may have past loans and/or deposits that are now closed, and documents can be provided to you, which show the reported SS#. Finally, federal tax filings and, if needed, having them sign IRS Form 4506 to get the tax documents released to show what SS# they're filing under, can provide you with verifying information.
Presumably if you were making a loan -- and you apparently did make the loan -- you could also validate the SS# when you obtained the credit report and conducted the underwriting assessment.
In making a loan and your not sure of the SS#, there is no rush and you have plenty of avenues to go in. Also, I can understand your concern if this is a personal loan (with no collateral), but if you have collateral pledged then I think you can generally assume this is not a high risk. The terrorists aren't getting home-equity loans; they're trying to open DDA, deposit or wire accounts that permit movement of cash to the U.S.
Absent any other indicators of a high-risk scenario, your mere mentioning of the borrower's etnicity as though it is part of your risk model is troubling. I would not be so quick to share this.
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#147031 - 01/08/04 05:38 PM
Re: Invalid SSN
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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I took the reference to ethnicity as suggesting the most likely explanation for why the bank was willing to make the loan even though the applicant did not have a valid SSN. It is no great surprise that a number of Mexican nationals are in the United States illegally and that banks are nevertheless accomodating their financial needs. Personally, I think the bank should have made a different decision.
Nevertheless, in order to see the the reference as a slur which I would be above making, I would need to be sitting on a high horse. In order to criticize it here, I would need to post anonymously.
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#147037 - 01/08/04 09:59 PM
Re: Invalid SSN
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Platinum Poster
Joined: Feb 2002
Posts: 582
USA
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According to our local police, an illegal alien usually purchases a complete set of documents to use while in this country. The names and numbers are frequently "recycled". We have seen the same name, DOB, SSN etc on multiple persons.
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#147038 - 01/08/04 10:14 PM
Re: Invalid SSN
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Power Poster
Joined: Jun 2003
Posts: 7,820
Florida
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Right now, I'm dealing with a QC issue where two independent verifications have come back that the "Input SSN have not been issued as of 12/03".
The next step (since the applicants have been at the same job for 2 years) is to have them sign a 4506 and see if the IRS has a record of the returns filed under the SSN's.
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Integrity. With it, nothing else matters. Without it, nothing else matters.
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#147039 - 01/08/04 10:16 PM
Re: Invalid SSN
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Jax, they should also receive a form 1040 through the mail in the next few days. Ask them to bring it in with the pre-printed label.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#147040 - 01/08/04 10:34 PM
Re: Invalid SSN
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Power Poster
Joined: Jun 2003
Posts: 7,820
Florida
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Quote:
they should also receive a form 1040 through the mail in the next few days.
Thanks for the reminder. After our request, I have a bet the'll "withdraw" the loan.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.
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#147042 - 01/08/04 11:38 PM
Re: Invalid SSN
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Anonymous
Unregistered
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Boomermom - Nobody is trying to peg you incorrectly, and it is understood why your interest would be piqued -- because, as was previously noted, a disproportionate number of fraudulent situations and other OFAC-related issues involve Hispanics. I'm aware of all that.
In your situation, however, you have a loan that you state your bank DID ultimately make to the borrower. Though you don't say what type of loan, I have to believe that the loan officer was ultimately satisfied that the unique identification of the borrower was established -- or else why would you be making unsafe/unsound loans. Therefore, noting that the borrower was Hispanic was a gratuitous remark. Assuming you are a compliance/risk person, you would know that there are many available options for validating an individual's identity -- again, a point noted previously.
Your error in judgement is minor compared to the so-called diamond discussers who offer useless drivel and lament over anonymous postings instead of offering mature, helpful discussions related to nondiscrimination in lending and other services; nondiscrimination in applications; and the existence of illegal disparate treatment. Because you noted that your institution HAD extended credit to the borrower, I was noting that your remark regarding the borrower's ethnicity was not relevant to the process for validating the applicant's identity and social security number. Again, your loan officer would have ample time to obtain numerous proof-of-identity documents prior to disbursing any funds -- and based on the loan having been made, this must have happened.
I have no axe to grind, and I'm not Hispanic nor an alien, but the respondents to your post are not the experienced posters who would have referenced the overt evidence of statements revealing explicit consideration of prohibited factors. Some of the posts use the uncapitalized term hispanic (sic); make other gratuitous references; and don't address the primary issue which is how your institution should address identity verification and validation when instances occur such as the questioned Social Security number. It is acknowledged that there is Social Security-card abuse, illegal immigration, and other bad things, but you made the loan. The Hispanic comment was and is gratuitous.
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#147045 - 01/09/04 05:35 PM
Re: Invalid SSN
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Anonymous
Unregistered
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Your story is just not credible anymore. Why would you now being calling the Social Security Administration when you've conceded your institution already extended credit to the borrower. The loan would not be sound if your institution did not establish the unique identity of the applicant prior to disbursing the loan proceeds.
There is no industry or regulatory pressure for any FFIEC- or state-supervised institution to extend credit to any individual where that person's true identity cannot first be validated. I can understand an institution opening a deposit account and putting a hold on the account until the verification/validity is completed, but I can't understand how an institution would extend credit to a loan applicant without this done. That your institution had an individual who ultimately was extended credit by a competent lending officer -- meaning a credit report was obtained, employment was verified, a mail address was obtained -- leaves me to believe that you fabricated the scope of the actual event, and your comment, " Oh, the customer is definitely Hispanic." was made for effect. You knew credit had been extended to the customer when you made the remark. My reply was that the remark is not one that should be shared, obviously because it is a remark that clearly indicates the existence of illegal disparate treatment through your statement -- made in your post -- that your institution explicitly considers prohibited, overt factors and different treatment for Hispanics.
My original point, made clearly, was that the main underlying issue should be for you to devise systematic, consistent incident response-type procedures or steps to address what you should do for any individual -- white, African-American, Hispanic, Asian, Native American -- whose identity is called into question.
You won't concede that your remark was unwarranted, and that it was done for effect to generate more posts that further generalized untrustworthiness of Mexicans/Hispanics, aliens, etc. My original remark was made not to question your competency, but to simply alert you that your personal thoughts should be more carefully shared. If you share them in a post, it's probably something you'd inadvertently say.
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#147047 - 01/09/04 07:02 PM
Re: Invalid SSN
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Anonymous
Unregistered
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Quote:
FYI - we have tried calling the Social Security Office for verification and they will not give out information except to the holder of the SSN in question.
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#147048 - 01/09/04 07:07 PM
Re: Invalid SSN
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Anonymous
Unregistered
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Obviously, we have an "anon" with too much free time on his hands.
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#147050 - 01/09/04 07:45 PM
Re: Invalid SSN
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10K Club
Joined: Aug 2002
Posts: 34,318
under the Lone Star
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Well, I hesitate to wade into this mess, but if the original anon's intent was to point out to our friend from Oklahoma the error of her ways (and please note I am not agreeing with anon), then he should have evailed himself of the private message system and not started public attacks. I don't think the motive was to be helpful, but the modus operandi of the famous unnamed poster from out West that Dan has fingered.
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