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Question: May the bank make loans to customers who only provide an ITIN?
Answer: Yes. In fact, the FDIC has published material in Supervisory Insights (Linking International Remittance Flows to Financial Services: Tapping the Latino Immigrant Market) that provides more info on ITINs and how to use them. For a non-US citizen, this number (which is issued by IRS) can be used as the identification number under the CIP rules.
Question: But what if the applicant has both an ITIN and SSN?
Answer: Now you have a potential SAR issue. Under the IRS rules, the ITIN is only available to persons who don't qualify for a SSN. Thus, possession of both could be an indicator of identity theft or fraud, according to the May 2007 SAR Review from FinCEN.
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