As Arlen said, for dependent card, they really don't need any information, other than the name of the person as you (the primary card holder) are responsible for everything.
My wife got credit card in her name (Not dependent) around 4 months ago. She have TIN number. She didn't apply for the card, one day she got pre-approved letter from DCU for the credit card. At first, I thought its same junk as other we receive every week but I didn't receive any junk from DCU in the pask. I call there CSR and asked, what is it and told them, she does not have a SSN and no credit history and she does not work. They said its OK and this really is a pre-approved letter for her and only she has to do is accept it.
In a week she got a credit card with thousands in credit line. I was amazed, how it happened.
PS. She had a checking account with DCU for about a year before she got this pre-approved letter.
To open a checking account too, same rules apply as applying a credit card (regarding SSN etc.). When did your wife open a checking account? That agent might have mistakenly given it to her thinking having checking account qualifies her. They were not supposed to issue since October 2003.
Well, the Patriot Act was enacted a week or so after 9/11. So, if they said this just came in effect in October, then it is not the Patriot Act. As I said, this all looks as if they are blowing smoke. If there is something new, the bank should be able to provide a copy of the law text, or at least the name of the law.
Also it may have taken time for banks to implement its provisions. They are not sure which part of the patriot act this guidline is at but they stand by what they say.