Federal Agencies Jointly Issue FAQs Concerning Customer Information Programs

The FRB, FDIC, FinCEN, NCUA, OCC, OTS and the U.S. Department of the Treasury (the "Agencies") jointly issued an updated set of frequently asked questions (the "FAQs") to provide interpretive guidance regarding the customer identification program requirements of Section 326 of the USA PATRIOT Act and the regulations thereunder (collectively, "Section 326"). Certain of the FAQs were originally issued in January 2004. Section 326 generally requires certain "financial institutions," including banks, thrifts, and credit unions (collectively "Banks") to establish and maintain Customer Identification Programs ("CIP") designed to verify the identity of their customers. Some of the key interpretations covered by the FAQs (including certain interpretations originally issued in January 2004) are as follows: