Can landlords require potental tenants to put their Social Security Numbers on Applications?
Question
Yesterday an applicant dropped off an application on which he failed to include his social security number. Can I require him to provide the number? Can I simply just reject the application if he refuses?
Answer
Refusal to provide a valid SSN would usually be an acceptable reason for rejection as long as that is something that the landlord requires from all applicants. The Fair Credit Reporting Act (FCRA) requires notice of rejection for credit reasons (not necessarily only related to a formal credit report) in the form of an adverse action report, but the fact that an applicant refuses to provide a Social Security Number probably waives this requirement because he did not complete the application in the first place.
If it were me, I’d call the person and tell him that his application cannot be processed unless a valid social security number is provided in writing within some specific short period of time. Make a memorandum of all facts regarding the matter, including any reason why he refuses to provide the information, and attach it to the application form.
To be safer, if he refuses to provide his SSN, you could send him written notice that his application is incomplete and cannot be processed. Also, be sure that your processing of applicants includes proof of identity (at least two IDs, with at least one being a photo ID), as it can be much worse to rent to an applicant who used a phony ID for which a great credit report is obtained than to rent to an honest person who has bad credit.