Collecting Identifying Information Required Under the Customer Identification Program (CIP) Rule

Summary:

The FDIC is issuing this advisory to reemphasize the requirements under the Customer Identification Program (CIP) Rule as it relates to collecting identifying information from customers. This advisory reminds institutions of the information required to be collected from the customer prior to account opening.

Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.

Highlights:

• In 2003, the final CIP Rule was issued for banks, savings associations, credit unions, and certain non-federally regulated banks.
• The CIP Rule requires a bank to implement a program that includes risk-based verification procedures that enable the bank to form a reasonable belief that it knows the true identity of its customers. These requirements exist regardless of whether the bank establishes this relationship directly with the customer or through an intermediary.
• These procedures must include collecting, at a minimum, the customer’s name, date of birth (for an individual), address, and identification number.
• A bank is required to collect the taxpayer identification number (TIN) from a customer that is a U.S. person prior to account opening or another approved identification from a non-U.S. person. This applies to all accounts with the exception of credit card accounts.
• To gain an understanding of the issues related to the TIN collection, FinCEN is seeking information and comment from banks and interested parties regarding the CIP Rule’s TIN collection requirement through a Request for Information: Customer Identification Program Rule Taxpayer Identification Number Collection Requirement.