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Regulatory Reform › Data Collection › Financial Institutions

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

A&O Shearman

FCA publishes consultation on streamlining data collection requirements

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published a consultation paper (CP) proposing the removal of reporting and notification requirements as part of its strategy to prevent unnecessary collection of data to reduce...more

Orrick, Herrington & Sutcliffe LLP

NCUA updates policy on overdraft and NSF fee data collection

Orrick, Herrington & Sutcliffe LLP on

On March 3, the NCUA announced changes to its policy on the collection and publication of overdraft and NSF fee income data from credit unions. Previously, the NCUA required federally insured credit unions with assets...more

Troutman Pepper Locke

Section 1071 Final Rule: Data Collection and Reporting

Troutman Pepper Locke on

As recently discussed on our podcast, section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) amended the Equal Credit Opportunity Act (ECOA) to require lenders to collect...more

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