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Collecting Credentials Required Under the Customer Identification Program (CIP) Rule

Collecting Credentials Required Under the Customer Identification Program (CIP) Rule

 


Summary:

The FDIC is issuing this notice to reemphasize the requirements of the Customer Identification Program (CIP) rule regarding the collection of identifying information from customers. This notice reminds establishments of the information that must be collected from the customer prior to opening the account.

Applicability Statement: The content and materials referenced in this FIL apply to all financial institutions supervised by the FDIC.

Strong points:

  • In 2003, the final CIP rule was published for banks, savings associations, credit unions, and certain non-federally regulated banks.
  • The CIP Rule requires a bank to implement a program that includes risk-based verification procedures that allow it to reasonably believe that it knows the true identities of its customers. These requirements exist regardless of whether the bank establishes this relationship directly with the customer or through an intermediary.
  • These procedures must include the collection, at a minimum, of the customer's name, date of birth (for an individual), address and identification number.
  • A bank is required to collect the Taxpayer Identification Number (TIN) of a customer who is a U.S. person prior to opening the account or other approved identification from a non-U.S. person. This applies to all accounts except credit card accounts.
  • To better understand the issues related to TIN collection, FinCEN is seeking information and feedback from banks and interested parties regarding the CIP Rule's TIN collection requirement through a Request for Information: Customer Identification Program Rule Taxpayer Identification Number Collection Requirement.

Related Resources:

Request for Information and Comments on the Customer Identification Program Rule on Taxpayer Identification Number (FinCEN) Collection Requirement

Customer Identification Program: Minimum Requirements (FinCEN)

Compliance Procedures: Customer Identification Program (FDIC)

FFIEC BSA/AML Examination Manual Procedures – Customer Identification Program

FAQ 2004 Final CIP Rule

Guidance on customer identification programs (FIL-34-2005)

Related topic:

Bank Secrecy Act

Sources

1/ https://Google.com/

2/ https://www.fdic.gov/news/financial-institution-letters/2024/fil24015.html

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