BSA/AML, CIP: Verify or Validate SSN's


When we open accounts, loans, etc. are we required to verify or validate SSN’s?


Yes, both lending an deposits must comply with the Customer Identification Program (commonly referred to as CIP) requirements.  Under CIP, before opening an account or extending credit, your bank must be reasonably satisfied that the customer is who they say they are. See 31 CFR §103.121(a)(1)(i).   In doing so, your bank must obtain the customer's name, address, date of birth, and identifying number. 31 CFR §103.121(b)(2) . Your bank must also verify this information. See 31 CFR §103.121(b)(2)(i).

The IRS has implemented a TIN Matching program.  You can learn more about it here.

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