Regulatory Alerts2025-06-27 | FIL-26-2025Added · Updated
Customer Identification Program Rule Exemption from Collecting Taxpayer Identification Number Information from Customers
FinCEN, the OCC, FDIC, and NCUA have jointly granted an optional exemption allowing banks under their jurisdiction to obtain Taxpayer Identification Number (TIN) information from third-party sources rather than directly from customers prior to account opening. Banks may utilize this alternative collection method provided they maintain risk-based written procedures that verify customer identity to a reasonable and practicable extent. The exemption addresses evolving non-face-to-face banking practices, consumer privacy concerns regarding data breaches, and the proven success of existing credit card account exceptions, thereby reducing compliance burdens without increasing money laundering or terrorism financing risks.
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