FinCEN Seeks Information In Efforts To Modernize CIP Rule

On March 29, 2024, the Financial Crimes and Enforcement Network (FinCEN) in collaboration with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Board of Governors of the Federal Reserve System (collectively, the Agencies), published a Notice for Information and Request for Comment (RFI). Specifically, the RFI seeks information from interested parties regarding the Customer Identification Program (CIP) Rule requirement for banks to collect, among other things, a taxpayer identification number (TIN) or Social Security number (SSN) for U.S. persons prior to opening an account (TIN Collection Requirement). Currently, the CIP Rule requires that for U.S. individuals, banks must collect a full SSN from the customer prior to opening an account.