Document Updates: Social Security Number Verification (Cx5579)

As previously announced, the SSA has published on their website a revised version of Form SSA-89. Our Cx5579 is a duplicate of this form and we are updating it to match the latest version.

New Fields

A major change between the previous and the current versions of the Form is the list of borrower reasons for authorizing consent to a company to verify their SSN (“Reasons”). The previous version permitted the borrower to select more than one Consent Based Social Security Number Verification (CBSV) Reason on the form; however, the new version only permits one CBSV Reason to be selected. In addition, the Reasons are different:

Due to this, we have created the following new fields:

• • Reasons for CBSV – Other Description (FI 141138)
  • Reasons for CBSV – To Apply For a Credit Card (FI 141139)
  • Reasons for CBSV – To Apply For a Job (FI 141140)
  • Reasons for CBSV – To Apply For a Loan (FI 141141)
  • Reasons for CBSV – To Open a Retirement Account (FI 141142)

In addition to these, we will continue to use the following existing fields for selecting the Reasons:

• • Reasons for CBSV – To Apply For a Mortgage (FI 67436)
  • Reasons for CBSV – To Open a Bank Account (FI 67439)
  • Reasons for CBSV – To Meet a Licensing Requirement (FI 67440)
  • Reasons for CBSV – Other (FI 67441)

Also, the singular line for listing the name and address of the agent of the company has been replaced by two separate lines. Therefore, we have created new fields for completing these lines:

• • SSA-89 Company Agent’s Address (FI 141144)
  • SSA-89 Company Agent’s Name (FI 141145)

We have also created two new fields for the company name and address that may be imported or mapped if needed. If these new fields are not used, the previous logic will be defaulted to.

• • SSA-89 Company Address (FI 141143)
  • SSA-89 Company Name (FI 141146)

Separate Copies Per Reason

Since only one Reason may be selected on the form, separate copies will need to print per Reason. This was by the design of the SSA, as explained by them in their answers to comments posed during the 30-day comment period for the information collection package which included new Form SSA-89 (see 86 FR 13967 [2020]):

“[Comment #2b] The form included in the eCBSV User Agreement [the new Form SSA-89] has a comment for the consumer to just select one purpose ‘(please select one).’ However, the form on the website includes a reference ‘(Please select all that apply).’ In cases when the consumer applies for two separate products at the same time, should we tell banks to display or allow consumer to select multiple purposes or just one?

SSA Response #2b: Consistent with the fillable SSA-89 that we expect will be the official Form SSA-89 in June 2020, consumers will need to complete an SSA-89 for each permissible purpose.” (see “Addendum to Supporting Statement for Electronic Consent Based Social Security Number Verification”; a copy is available upon request)

To accommodate this, separate copies should print for each of the “Reasons” fields set forth in the previous subsection, when these fields are selected. As explained in the next section, this functionality is being prepared for future rollout, but at this time a separate “ink sign” copy will need to be manually copied for each additional Reason the borrower wishes to select.

ESIGN and Plans for the Future

Current SSA policy regarding Form SSA-89 is that it must be “ink signed” by the borrower. This policy will change with the new eCBSV, the User Agreement for which holds that the borrower has given valid Written Consent for verifying the borrower’s SSN through Form SSA-89 when it is “in a ‘pdf fillable’ form, signed electronically by the SSN holder, with an Electronic Signature that meets” SSA’s requirements (see “eCBSV User Agreement” § IV.1.b; available at: https://www.ssa.gov/dataexchange/eCBSV/index.html#ua).

We asked the SSA for further clarification on this and they provided a response, as follows:

“Comment #9: A commenter asked can a document vendor create an electronic copy of Form SSA-89, pre-populate the fillable parts of the form using data imported from a mortgage lender’s loan origination system, and have the SSN holder electronically sign such copy (which can be saved into PDF format)? Or must Form SSN-89 [sic] always be provided to an SSN holder in ‘pdf fillable’ form to be filled out manually by the SSN holder?

SSA Response #9: Yes, a document vendor may create an electronic copy of Form SSA-89, pre-populate the fillable parts of the form using data imported from a mortgage lender’s loan origination system, and have the SSN holder electronically sign such copy, as long as the form is not altered in any way and the SSN holder has an opportunity to review/correct any ‘auto-populated’ information prior to signing the SSA-89.

The document vendor must replicate the SSA-89 in its entirety so as not to alter the purpose of the form.” (see “Addendum to Supporting Statement for Electronic Consent Based Social Security Number Verification”; a copy is available upon request)

Based on this feedback, if Cx5579 were permitted to be electronically signed: (1) the borrower must be permitted to change the data points within the document in Solex; and (2) if the borrower selected or de-selected any of the Reasons within Solex, such selection or deselection must cause the number of copies of the form to increase or decrease, as a result.

We are currently working on solutions for these two points. Because the eCBSV (which is the only system for which electronic copies of Form SSA-89 are valid) is still in its “testing” stages, with universal rollout expected sometime later this year, Cx5579 will continue to be configured to be “ink sign” only while we work on this functionality, and will only print one copy per borrower, as it has in the past.

Effective Date

The SSA has stated that their new 12-2020 version of Form SSA-89 must be used by September 30, 2021. Because the form is available on their website, it is safe to assume that it can be used now, therefore these changes will take effect on January 20, 2021 January 27, 2021. Note that the Spanish copy of the SSA-89, Cx22142, is also being changed. These changes are available now on Stage servers for testing. Note that those clients with custom copies of the SSA-89 must request that their copies be updated.

Any questions or concerns about these changes should be directed to Client Support at 1.800.497.3584. To obtain a copy of the “Addendum” referenced (which is no longer available on the SSA’s website), please email Timothy A. Raty at traty@firstam.com.

DR 335144

Update: We have created a new document-triggering Multi-Doc Collection (MDC) that satisfies the requirement that borrowers will need “an SSA-89 for each permissible purpose”. Essentially, the document will generate one copy for each of the following fields, OR will print a single copy with none of the “Reasons for CBSV” checked, if none of the fields are filled out:

• Reasons for CBSV – To Apply For a Mortgage (FI 67436)
• Reasons for CBSV – To Open a Bank Account (FI 67439)
• Reasons for CBSV – To Apply For a Credit Card (FI 141139)
• Reasons for CBSV – To Apply For a Loan (FI 141141)
• Reasons for CBSV – To Open a Retirement Account (FI 141142)
• Reasons for CBSV – To Apply For a Job (FI 141140)
• Reasons for CBSV – To Meet a Licensing Requirement (FI 67440)
• Reasons for CBSV – Other (FI 67441)

Due to client requests for more testing time, the announcement period has been extended out to January 27, 2021. These changes for the MDC will be pushed out to be live in conjunction with the other changes on January 27, 2021.

Update 1/27/2021: