On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account. The order applies to all accounts at all banks and credit unions supervised by these entities and alters the Customer Identification Program Rule (CIP Rule) implementing section 326 of the USA PATRIOT Act. The section provided that banks must obtain TIN information directly from the customer; however, the new exemption will permit banks and credit unions to use an alternative method to collect TIN information, such as from a third-party source rather than from the customer. The use of this exemption is optional; banks and credit unions are not required to use an alternative collection method for TIN information. The agencies cited changes in industry practices, increased consumer privacy concerns, and the availability of new identity verification tools as reasons for the exemption.
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