Industry-Wide (All Banks and Credit Unions)
On June 27, 2025, five federal agencies — OCC, FDIC, Federal Reserve, NCUA, and FinCEN — issued a Customer Identification Program (CIP) exemption order permitting banks and credit unions to obtain TINs from third-party sources rather than requiring direct customer submission during account opening. The order was expanded on July 31, 2025. This directly supports bank-fintech partnerships by reducing onboarding friction in digital account opening workflows. Banks must still maintain risk-based CIP procedures to verify customer identity. The measure is designed to promote financial inclusion and align regulatory requirements with modern digital verification tools commonly used in BaaS and embedded finance models.
Verified from source: OCC, FDIC, and NCUA, with FinCEN concurrence, issued an order on June 27, 2025 permitting banks to collect customers' TINs from third parties rather than directly from customers. The Federal Reserve Board joined the order on July 31, 2025, aligning all federal banking agencies and FinCEN on updated CIP Rule requirements.
- Reduces onboarding friction for BaaS and embedded finance programs that rely on digital account opening
- Legitimizes use of third-party data sources in CIP compliance, benefiting fintech-bank partnerships
- May accelerate digital-first account opening flows and expand financial inclusion
- Banks must ensure risk-based CIP procedures remain robust even when using third-party TIN sources