In a letter today, the American Bankers Association shared banker feedback on a Financial Crimes Enforcement Network request for information about the potential consequences of a possible change to the Customer Identification Program rule. Under the CIP rule, most banks must collect a full nine-digit taxpayer identification number from U.S. customers before opening accounts, which is usually their Social Security number. Although there is no proposal yet to do so, FinCEN and banking agencies are contemplating letting banks collect only part of an SSN from customers as long as they use reputable third-party sources to obtain the full SSN before account opening.
ABA is not taking a position regarding any possible rule change but submitted input from bankers on the collection requirement, focusing on accuracy, cost and fraud prevention. For example, if banks no longer need to collect a full SSN, then FinCEN needs to clarify that a revised CIP rule does not increase inefficiencies by requiring banks to engage with two third parties to verify information, the association said. At the same time, customers may value the ability to only provide the last four digits of their SSN, so banks that compete with entities that do not need to collect the full nine-digit SSN from customers prior to account opening should not be competitively disadvantaged. The agency should also seek feedback from banks and third-party service providers regarding costs associated with changes to the current CIP rule, it added
