Must all new account customers verify SS #

Answered by:

Question:

When opening an account for a new customer must the individual present his or her social security card or provide documentation to verify the SS#, as a result of the provisions of the USA PATRIOT Act? Is not providing the SS# along with proper ID enough? Many individuals don't have anything with the SS# on it or carry it with them. We don't want to turn prospective account holders away for not having their SS Card.

Answer:

Answer by Jim Bedsole:

There is no requirement in the CIP regulations that specifically requires you to verify the SSN. You are required to verify identity under a riskbased program.Most savvy consumers have stopped carrying on their persons anything with their SSN.

Answer:

Answer by Ken Golliher:

CIP will require you to get the TIN. It is one of the pieces of customer information you may choose to verify and seeing the source document allows you to do that. However, there is no requirement that you see the Social Security card with the SSN or the letter from the IRS awarding an EIN.

I don't carry a Social Security card. I lost it at 16 and have not needed it since. As John notes, others have simply made an informed decision not to carry it. Making the source document a condition of opening the account would be overly restrictive.

Currently, non documentary verification of an SSN is only possible in a limited sense in that you can tell where the number was issued, when it was issued and whether this person has used it before from some commercially available data bases. SSA and IRS are partnering on a system that would actually allow you to verify name/TIN combinations, but it is not operational as yet.

First published on BankersOnline.com 06/2/03