The Financial Crimes Enforcement Network (FinCEN) is issuing a request for information (RFI) related to existing requirements for banks under the Customer Identification Program (CIP) Rule to collect a taxpayer identification number (TIN) from a customer prior to opening an account.
Generally, for a customer who is an individual and a U.S. person, banks are required to collect a full Social Security number (SSN) from a customer. This RFI will inform FinCEN’s understanding in this area and evaluate the risks, benefits, and safeguards if banks were permitted to collect partial SSN information from a customer and subsequently use reputable third-party sources to obtain the full SSN prior to account opening.
This RFI also reminds banks of the requirement to collect identifying information from the customer prior to opening an account. Comments to the RFI will be accepted for 60 days following publication in the Federal Register.
News Release: https://fincen.gov/news/news-releases/fincen-seeks-comments-customer-identification-program-requirement
Federal Register Notice: https://fincen.gov/resources/statutes-regulations/federal-register-notices/request-information-customer-identification
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