The requirement that banks collect identifying information “from the customer” under the Customer Identification Program rule does not preclude the use of pre-populated information, the FDIC said today.
In a financial institution letter, the FDIC said it is updating its supervisory approach regarding the use of pre-populated information to fulfill CIP requirements. One example is opening of an account electronically where fields in a digital form are automatically pre-populated, or “pre-filled,” with a customer’s identifying information.
“Under the FDIC’s interpretation, a financial institution could use information from current or prior accounts or relationships involving the bank or its agents, or other sources, such as parent organizations, affiliates, vendors and other third parties to pre-fill information that is reviewed and submitted by the customer,” the agency said. “The FDIC considers such information from the customer for purposes of the CIP rule.”
FDIC examiners will consider the pre-filled information as from the customer if he customer has opportunity and the ability to review, correct, update and confirm the accuracy of the information, and if the institution’s processes for opening an account that involves pre-populated information allows it to form a reasonable belief as to the identity of its customer and are based on the institution’s assessment of the relevant risks, including the risk of fraudulent account opening or takeover.
