Reasonable actions on inability to verify
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Although a compliance system is essential to unifying and streamlining compliance within an organization,
even the best system requires human intelligence. Day to day operations require knowledge of the
guidelines and regulations and surrounding the USA Patriot Act. This section attempts to outline various ways
of handling list matches and identify verification failures by providing resources and information to our
valued customers.
For more information on conducting enhanced due diligence, click here.
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| Non matching
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Last Name
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Address
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SSN/ITIN
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DOB
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Possible Reasons
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√ Maiden Name
√ Change of Name
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√ Change of address
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√ Child
√ No credit history
√ Non resident
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√ Not furnished
√ Non resident
√ Credit header incorrect
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Possible Solution
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√ Marriage license
√ Drivers License
√ Interested party confirmation
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√ Validate prior address match
√ Contact customer for previous address
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√ Obtain W-9,8,7
√ Request customer complete SS-5
√ SSN card
√ Passport Number and country issued
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√ Driver's License
√ SSN card
√ Birth Certificate
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W-7: application for IRS Individual Taxpayer
Identification number (ITIN). A TIN number can also be a SSN number.
Resident aliens who cannot be given an SSN use their IRS individual
taxpayer identification number (ITIN) as their TIN.Get form at
www.irs.gov.
W-8: see above, but for a disregarded domestic
entity (aka:company (LLC)) that has a foreign owner.
W-9:a tax form which certifies the ITIN
number. Can also certify that your SSN is correct.
SS-5 form: application for an
SSN card (for newly issued card, replacement card, or name change). Get
form at www.ssa.gov.
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