On March 29, the Federal Crimes Enforcement Network (FinCEN), in collaboration with other federal agencies, issued a Notice and Request for Information and Comment (Notice and Request) seeking public comment on its proposal to amend the Customer Identification Program (CIP) Rule requirement for banks to collect a taxpayer identification number, among other information, from a U.S. customer prior to opening an account. Usually, for a U.S. customer this requires banks to collect a full Social Security number (SSN). The amendment comes in response to pressure from fintechs, specifically providers of buy-now, pay-later products that rely on bank partners, for an accommodation from the CIP Rule.

In the press release announcing the Notice and Request, FinCEN Director Andrea M. Gacki. stated, “The requirement for banks to collect identifying information from a customer prior to opening an account has been a long-standing component of a bank’s anti-money laundering program. However, FinCEN recognizes the significant changes in technology and financial services that have taken place since promulgation of the CIP Rule, and we welcome comments from interested parties as we explore ways to modernize the U.S. anti-money laundering/countering the financing of terrorism regime.” Specifically, FinCEN in seeking information to inform its 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.

FinCen will accept written comments on the Notice and Request until May 28, 2024.