HUD's FAQs - The Definition of Application Includes the Social Security Number as One of Six Pieces of Information. Foreign Nationals Do Not Have Social Security Numbers. Is a Tax Identification Number (TIN) an Acceptable Substitution?

Compliance > Regulation X - RESPA > GFE and HUD-1 > HUD's FAQs
Q: The definition of application includes the social security number as one of six pieces of information. Foreign nationals do not have social security numbers. Is a Tax Identification Number (TIN) an acceptable substitution?

A: Before a loan originator issues a GFE, the loan originator will often evaluate the credit worthiness of a potential borrower by pulling an "in-file" or a credit report. The social security number is typically the unique identifier used to pull a credit report. If the social security number is not the appropriate unique identifier necessary to determine a borrower‘s credit worthiness, another unique identifier may be substituted.

This can be found in GFE-General – FAQ #14 of HUD’s FAQs.  HUD’s FAQs can be found at

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