Compliance Blog

Posted by Anthony Demangone

Recently, NCUA issued guidance, along with other regulators, on cross-border transactions.  Here's a link to a NAFCU Today article, which also links to the guidance.  I'd focus on page 4 of the guidance, which outlines what examiners should focus on.

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Do you have to include a SSN on 1099s?  Yes and no.  According to this IRS notice (IRS Notice 2009-93), the IRS created a pilot program for calendar years 2009 and 2010 to try out the idea of truncating taxpayer identification numbers.  But only on the paper payee statement for the 1099, 1098 and 5498 series for now.  Read the notice in its entirety, as there are some qualifications to the general pilot program.

This notice creates a pilot program allowing filers of information returns to truncate an individual payee’s nine-digit identifying number on paper payee statements for calendar years 2009 and 2010 if the filers meet the requirements set forth in this notice. This notice only applies to paper payee statements in the Form 1098 series, Form 1099 series, and Form 5498 series. Filers who meet the requirements in this notice will be treated as having satisfied any requirement in Treasury and IRS guidance, whether in a regulation, form, or form instructions, to include a payee’s identifying number on a payee statement.