Federal Deposit Insurance Corporation updates supervisory approach allowing pre-populated customer information for Customer Identification Program compliance

The Federal Deposit Insurance Corporation issued supervisory guidance updating how it will assess the use of pre-populated customer identifying information during account opening for purposes of Customer Identification Program (CIP) requirements. The guidance applies to all FDIC-supervised financial institutions and reflects the FDIC’s position that the CIP rule’s requirement to collect identifying information “from the customer” does not, by itself, prohibit the use of pre-filled fields that a customer reviews and submits. In examinations, FDIC staff will treat pre-populated information as collected from the customer if the customer has the opportunity and ability to review, correct, update, and confirm the information’s accuracy, and if the institution’s account-opening processes enable a reasonable belief as to the customer’s identity based on the institution’s assessment of relevant risks, including fraudulent account opening or account takeover. The FDIC noted that pre-filled data may be sourced from current or prior accounts or relationships involving the bank or its agents, and from other sources such as parent organizations, affiliates, vendors, and other third parties.