Social Security Numbers
Social Security numbers have become a key element many aspects of life in the United States. Recent developments restrict the availability of Social Security numbers for foreign nationals. The following resources are intended to provide resource documents for understanding the role of SSNs in various parts of U.S. business/society. Practice Tools provided on this site are intended to serve only as an exampls of what an institution has prepared for their own use. The information provided does not constitute legal advice — it is provided for informational purposes only.
May 29, 2007, presentation by James Leck (Boston University), Richard Porter (University of Missouri-Columbia), and Helene Robertson (The Catholic University of America) at NAFSA:Association of International Educators conference in Minneapolis, Minn.
Reports & Audits Ongoing criticisms of the Social Security Administration's enumeration policy led to a tightening of Social Security number eligibility.
Reports: Universities' Use of Temporary SSNs (April 26, 2004); A series of reports on universities' use of SSNs as student identifiers by Region: Region 1 Boston (08/12/2005), Region II - New York (7/27/2005), Region III - Philadelphia (4/26/2005), Region IV - Atlanta (12/9/2004), Region V - Chicago (6/7/2005), Region VI - Dallas (8/19/2005), Region VII - Kansas City (01/31/2005), Region VIII - Denver (3/21/2005), Region IX - San Francisco (11/30/2005); Region X - Seattle (3/8/2005)
SSA Regulations and Guidance
Compilation of Social Security Laws; 20 CFR 422; December 2007 letter from SSA regarding enumeration of F-1 students; link to Social Security Administration's section of their Program Operations Manual System (POMS) that describes enumeration policies and procedures; International Student Fact Sheet 3/2004 (includes section on working without an SSN); Types of Social Security cards; Final Rule 9-13-2004 on F student enumeration; excerpts from Social Security Act; SSN mismatch policy; SSA's sample letter for schools;Internationals and SSNs Fact Sheet 12/2005SSA website; information to employers when hiring foreign employees (includes basic information on how to handle employees who have applied for, but not yet received SSN). IRS guidance on lack of SSN at start of employment.
PRACTICE TOOLS: CUA SSN handout (adapted from the one created by the University of Pittsburgh); NAFSA Practice Advisory on Evidentiary Changes for F-1s; NAFSA practice Advisory on SSNs; SSN Application Flow Chart; Memo from CUA General Counsel (as posted on NAFSA website).
DHS/SAVE System for Verifying immigration status of SSN applicants
August 15, 2007, Federal Register Final Rule regarding safe harbor procedures for employers who receive no-match letters
October 28, 2008, Federal Register Supplemental Final Rule clarifying safe harbor procedures for employers who receive no match letters - regulatory flexibility analysis
Banking: Banks are legally required to verify the identity of all their customers by establishing a "Customer Identification Program."
Guidance on Bank Secrecy Act; Excerpt from PATRIOT ACT, Information on required "Customer Information Programs": Treasury Customer Identification Program 31CFR103.121; CIP Final Rule; comments on rule; Treasury guidance to Federal Reserve Banks; Treasury CIP FAQ, Fact Sheet 4-30-03, Fact Sheet 9-18-03, CIP guidance; Office of Thrift Supervision implementation guidance
DOL It is critical to understand who is an employee when deciding who needs a Social Security number
PRACTICE TOOLS: CUA chart on Employee vs. Volunteer
Individual Taxpayer Identification Number
26 CFR 31-6011; ITIN changes 12-2003; About ITINS; Form W-7; Form W-8BEN; Form W-8BEN instructions; Internal Revenue Bulletin 04-02 (highlights have been added to this document to help find relevant sections); IRS Publication 515 for 2004; Taxpayer Assistance Centers
Check out the following Web page for more information on the REAL ID Act and Drivers Licenses