Regulatory Alerts2025-06-27
Exemption Order Related to TIN Collection and Customer Identification Program Requirements
The OCC, FDIC, and NCUA, with FinCEN's concurrence, have granted an exemption allowing banks to obtain Taxpayer Identification Number information from third-party sources rather than directly from customers. This optional measure permits alternative collection methods for all accounts at regulated banks, provided the institutions maintain risk-based written procedures to verify customer identity prior to account opening. The Agencies determined that this flexibility addresses consumer privacy concerns and aligns with modern non-face-to-face banking practices without increasing money laundering or terrorism financing risks.
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