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 granting an exemption from a requirement in the Customer Identification Program (CIP) Rule implementing Section 326 of the USA PATRIOT Act. The exemption permits banks and credit unions to use an alternative method to obtain a customer’s taxpayer identification number (TIN) from a third party, rather than collecting it directly from the customer before opening an account. The order applies to accounts at all entities supervised by the three agencies and is optional. The agencies pointed to changes in how consumers access financial services and increased reluctance to provide full TINs, including due to data breaches and identity theft concerns, while noting that institutions must still maintain risk-based CIP procedures that enable them to form a reasonable belief they know the true identity of each customer.
Office of the Comptroller of the Currency 2025-06-27
US Office of the Comptroller of the Currency, FDIC and NCUA issue exemption order allowing third-party collection of taxpayer identification numbers under the Customer Identification Program Rule
The Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union Administration, with Financial Crimes Enforcement Network's concurrence, exempted banks and credit unions from directly collecting taxpayer identification numbers under the Customer Identification Program Rule. This allows third-party methods to obtain TINs, addressing consumer reluctance due to data breaches and identity theft concerns. Institutions must still maintain risk-based procedures to verify customer identities.