How do firms like BillMeLater get away with requesting only the last four digits of an SSN for CIP/Patriot Act compliance?
Money Transmitter License
Asked by Question Bot05/Jan/20151 answer
1 Answer
F
Faisal Khan
Answered 05/Jan/2015
Because their Anti-Money Laundering (AML) manual allows them to do so. One need not need the entire SSN to verify a person. Plenty of services will very a person based on their name, DOB, Address and last 4 digits of the SSN.
They are not getting away with anything, its just this is the minimum information that is required to very accurately identity and do KYC on a person.
In the ID process, if more information is required of the person, the company has the right to ask for full SSN. In some instances, companies have slabbed policies:
Each company will set its own flexibility criteria. Just to be clear, an SSN is not mandatory provided certain financial limits are not breached.
They are not getting away with anything, its just this is the minimum information that is required to very accurately identity and do KYC on a person.
In the ID process, if more information is required of the person, the company has the right to ask for full SSN. In some instances, companies have slabbed policies:
- Limit: Under $500/day and under US$ 2,500 per month (just Name, Address, Telephone is required)
- Limit: Under US$ 2,500 per day and under US$ 7,500 per month (Name, Address, Telephone, DOB, Last 4 SSN and One Photo ID)
- Limit: Under US$ 5,000 per day and under US$ 25,000 per month (Name, Address, Telephone, DOC, Last 4 SSN, 1 Photo ID and 1 Utility Bill copy in your name, reflecting the Address you have listed).
Each company will set its own flexibility criteria. Just to be clear, an SSN is not mandatory provided certain financial limits are not breached.