Regulatory Alerts2025-08-05 | FIL-39-2025FDIC Supervisory Approach Regarding the Use of Pre-Populated Information for Purposes of Customer Identification Program Requirements
The FDIC updates its supervisory approach to permit supervised institutions to satisfy Customer Identification Program (CIP) requirements by using pre-populated customer information during account opening. Institutions must ensure customers can review, correct, and confirm the pre-filled data while maintaining risk-based processes that establish a reasonable belief of customer identity. This interpretation explicitly allows leveraging existing records, affiliates, vendors, or third parties without violating the CIP rule’s mandate to collect identifying information “from the customer.”
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