November 21, 2025

Vol. XLII, No. 12

CIP/TIN Verification Exemption

The federal banking agencies have issued an Order allowing banks and their subsidiaries to collect Tax Identification Number (TIN) information from a third party rather than directly from the bank's customer at account opening. This is an exemption to the existing Customer Identification Program (CIP) Rule requirement under the Bank Secrecy Act (BSA).

With this Order, instead of having to collect the full nine-digit TIN directly from the customer, banks subject to the CIP Rule are now permitted to collect TIN information from a third-party source rather than directly from the customer when opening a new account and need only collect the last four digits of the TIN from the customer.

The exemption provides an alternate and optional path to the existing one, whereby banks collect full TIN information directly from the customer. The order makes clear that banks are not required to use this alternative collection method, mitigating concerns expressed by certain banks with respect to having limited resources available for such third-party identity verification services. The Order emphasizes that banks pursuing this alternate method must still demonstrate their ability to form a reasonable belief they know the true identity of each customer.

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The foregoing Compliance Update is for informational purposes only and does not constitute legal advice. As a reminder, the NBA general counsel is the attorney for the Nebraska Bankers Association, not its member banks. The general counsel is available to assist members with finding resources to help answer their questions. However, for specific legal advice about specific situations, members must consult and retain their own attorney.