The Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the National Credit Union Administration, with the concurrence of the Financial Crimes Enforcement Network, issued an order exempting supervised banks and credit unions from the Customer Identification Program (CIP) rule requirement to obtain a customer’s taxpayer identification number (TIN) directly from the customer before opening an account. The exemption allows institutions to use an alternative method to obtain TIN information from a third party. The order applies to accounts at all entities supervised by the three agencies and is optional. It does not change the underlying CIP rule requirement, which implements Section 326 of the USA PATRIOT Act, for banks and credit unions to maintain risk-based CIP procedures that support a reasonable belief they know the true identity of each customer; the exemption is framed as providing flexibility amid changes in how consumers access financial services and increased customer reluctance to provide full TINs due in part to data breaches and identity theft concerns.
National Credit Union Administration 2025-06-27
Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and National Credit Union Administration grant optional Customer Identification Program exemption allowing third-party collection of taxpayer identification numbers
The Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union Administration, with Financial Crimes Enforcement Network's concurrence, exempt banks and credit unions from obtaining a taxpayer identification number (TIN) directly from customers before account opening. This allows third-party methods for TINs, offering flexibility due to evolving consumer access and data breach concerns. The Customer Identification Program rule remains unchanged, requiring risk-based procedures to verify identities.