Regulatory AlertsSR 20-23: Interagency Order Granting an Exemption from Customer Identification Program Requirements for Premium Finance Loans
The Federal Banking Agencies and FinCEN issued an interagency order granting an exemption from Customer Identification Program requirements for premium finance loans extended by banks to all customers. This order supersedes a 2018 exemption that was limited to commercial customers, thereby extending the relief to individual borrowers as well. The exemption is justified by the low money laundering risk associated with these short-term loans and the fact that they are secured by unearned insurance premiums.
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