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Regulatory Reform › Customer Identification Program (CIP) › FinCEN

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Bradley Arant Boult Cummings LLP on

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

Morrison & Foerster LLP on

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Troutman Pepper Locke

FDIC Acting Chairman Hill Supports Modernizing Customer Identification Program Requirements

Troutman Pepper Locke on

In a recent letter to Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill expressed his support for updating the Customer...more

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