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

Summary:

The FDIC is issuing this notice to reemphasize the requirements under the Customer Identification Program (CIP) Rule as it relates to the collection of customer identifying information. This notice reminds institutions of the information that must be collected from the customer before opening the account.

Applicability statement: The content and material referenced in this FIL apply to all financial institutions supervised by the FDIC.

Reflexes:

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 allow the bank to have 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 client or through an intermediary.

These procedures must include collecting, at a minimum, the client's name, date of birth (for an individual), address, and identification number.

A bank must collect the taxpayer identification number (TIN) of a customer who is a U.S. person before opening the account or other approved identification of a non-U.S. person. This applies to all accounts except credit card accounts.

To understand the issues surrounding TIN collection, FinCEN is seeking information and comments from banks and stakeholders on the CIP rule's TIN collection requirement through a Information Request: Customer Identification Program Rule Taxpayer Identification Number Collection Requirement.