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ARTICLE · 05 APRIL 2024

FinCEN Requests Comments Regarding Possible Relaxation Of Banks' Customer Identification Program Requirements

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The current CIP rule remains in effect, and requires banks to collect all nine digits of SSNs directly from U.S. individual customers before opening an account for them...

United StatesFinance and Banking
Anand Sithian
Anand Sithian
Carlton Greene
Carlton Greene
Caroline E. Brown
Caroline E. Brown
Nicole Sayegh Succar
Nicole Sayegh Succar

What You Need to Know

  • Key takeaway #1
    The current CIP rule remains in effect, and requires banks to collect all nine digits of SSNs directly from U.S. individual customers before opening an account for them, except in the case of credit card accounts.
  • Key takeaway #2
    Banks that rely on third-party service providers to collect SSNs for the opening of accounts should make sure that these providers are collecting all nine digits directly from customers to avoid a potential CIP compliance issue. Conversely, FinTechs and banking-as-a-service providers should assess whether they collect full SSNs from prospective customers in connection with services offered through banks, and should prepare for diligence requests from their bank partners on this issue.

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