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New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

One Step Closer to Certainty: Court Dismisses States' Challenges to "Valid When Made" Rules

On February 8, 2022, a federal district court in California issued separate orders concluding that the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) did not violate the...more

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