Banks may use pre-populated customer information to satisfy Customer Identification Program (CIP) requirements when opening an account, the federal bank deposit insurance agency said late Tuesday.
In a financial institution letter (FIL), the Federal Deposit Insurance Corp. (FDIC) said rules implementing CIP (under the USA PATRIOT Act of 2001) requiring collection of identifying information “from the customer” do not preclude the use of pre-filled information.
A commonly encountered example is the opening of an account electronically where fields in a digital form are automatically pre-populated (or “pre-filled’”) with a customer’s identifying information, the FDIC said in its FIL 39-2025.
“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 wrote. “The FDIC considers such information from the customer for purposes of the CIP rule.”
The agency said examiners would consider the pre-filled information as from the customer under two conditions: the customer has opportunity and the ability to review, correct, update, and confirm the accuracy of the information, and; the institution’s processes for opening an account that involves pre-populated information allow the institution 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.
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