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ARTICLE · 08 AUGUST 2025

FDIC Clarifies That CIP Rule Does Not Preclude Using Pre-populated Customer Information

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On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer...

United StatesFinance and Banking
Kristen Larson
Kristen Larson
Ronald K. Vaske
Ronald K. Vaske
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On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer information to satisfy the requirements of the Customer Identification Program Rule, implementing part of the USA PATRIOT Act (CIP rule).

The CIP rule requires financial institutions to collect information (name, address, date of birth, and taxpayer identification number) from persons opening accounts and to verify the person's identity. The FDIC opined that the requirement to collect identifying information from the customer under the CIP rule does not preclude the use of pre-filled identifying information and that the FDIC would consider such pre-filed information as having been obtained from the customer for purposes of the CIP rule.

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