In our July 23rd blog, we alerted you to the fact that FinCEN had issued an Order providing banks with greater flexibility when it comes to obtaining customer tax identification numbers (TINs). The Order was issued in conjunction with the OCC, FDIC and NCUA and since that time, a subsequent Order was also issued in conjunction with the Federal Reserve. The Orders allow banks to obtain TIN information for a customer from a third-party rather than directly from the customer. We covered this in more detail, along with possible implications and things to consider, in our August issue of Banking on BCC.
On August 5th, the FDIC went a step further and issued FIL-39-2025 announcing its updated supervisory approach regarding whether an FDIC-supervised institution can use pre-populated customer information for the purpose of opening an account to satisfy Customer Identification Program (CIP) requirements. CIP requires an institution to collect certain information “from a customer” opening an account; however, the FDIC will now allow that information to be pre-filled/populated from other sources, such as current or prior accounts, affiliates, vendors, etc. that is then reviewed by and submitted by the customer. This will most likely come into play with online account opening, online loan applications, etc.
The FIL states: When examining an FDIC-supervised institution that collects identifying information from a customer where some or all of the information was pre-populated, FDIC examiners will consider the pre-filled information as from the customer provided that (1) the customer has opportunity and the ability to review, correct, update, and confirm the accuracy of the information, and (2) the institution’s processes for opening an account that involves pre-populated information allow the institution to form a reasonable belief as to the identity of its customer and are based on the institution’s assessment of the relevant risks, including the risk of fraudulent account opening or takeover.
Published
2025/08/11