What's New? TIN Alternative Collection Methods


On June 27, 2025, the FDIC, OCC, and NCUA, with the concurrence of FINCEN, issued an order granting an exemption from a requirement of the Customer Identification Program (CIP) Rule implementing Section 326 of the USA PATRIOT Act. The CIP Rule requires financial institutions to obtain a Taxpayer Identification Number (TIN) information from its customer before opening an account.
The regulatory order allows financial institutions to use an alternative collection method for obtaining TINs under the CIP rule. Instead of directly collecting the TIN from the customer, institutions can now obtain it from a reliable third-party source. This change aims to reduce friction in account opening and enhance data security, particularly in online banking.
Read more in The Gold Book under Customer Identification Program, (TIN) Alternative Collection Methods.


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