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Financial Services News Roundup
July 25, 2025 – August 14, 2025

Agencies Permit Banks and Credit Unions to Obtain Customer TINs from Third Parties

Welcome to Goodwin’s Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking.
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0Agencies Permit Banks and Credit Unions to Obtain Customer TINs from Third Parties

On July 31, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration, and the Financial Crimes Enforcement Network (FinCEN) (collectively, the Agencies) issued an order aimed at providing banks and credit unions flexibility to use third-party sources to obtain tax identification numbers (TINs), rather than requiring banks and credit unions to obtain the TINs directly from customers. Enacted in 2003, the Customer Identification Program (CIP) rule (31 C.F.R. § 1020.220), which implements Section 326 of the USA PATRIOT Act (the CIP Rule), requires banks and credit unions to verify the identity of any potential customer by obtaining certain identifying information prior to account opening, including obtaining a TIN, if the customer is a US person. Due to recent reluctance by customers to provide their TIN arising from concerns over data breaches and identify theft, the Agencies’ new exemption aims to provide banks and credit unions with greater flexibility to change their method of TIN collection, while still requiring banks and credit unions to comply with all other regulatory requirements under the CIP Rule. Use of the exemption is optional, and banks and credit unions are not required to use alternative collection methods.

0FDIC Interprets CIP Rule to Allow for Pre-Populated Customer Information at Account Opening

On August 5, the FDIC issued an interpretation of the CIP Rule to clarify that an FDIC-supervised institution can use information from current or prior accounts or relationships involving the bank, its agents, or other sources (e.g., parent organizations, affiliates, vendors, third parties) to pre-fill information that is reviewed and submitted by the customer. Such pre-populated information will be viewed by the FDIC as satisfying the CIP Rule requirements if (1) the customer has the opportunity and ability to review, correct, update, and confirm the accuracy of the information, and (2) 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.

0CFPB Seeks Comment on Increasing Threshold for Defining Larger Participants in Certain Markets

On August 8, the Consumer Financial Protection Bureau (CFPB) issued advance notices of proposed rulemaking for the automobile financing market, consumer reporting market, international money transfer market, and consumer debt collection market, seeking information from market participants to help the CFPB  decide whether to propose a rule that would increase the threshold for defining larger participants in each market. Each notice includes a list of questions for commenters, including whether the current threshold is appropriate and how changing the threshold may impact costs for participants and consumers. Comments must be received on or before September 22, 2025.

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This informational piece, which may be considered advertising under the ethical rules of certain jurisdictions, is provided on the understanding that it does not constitute the rendering of legal advice or other professional advice by Goodwin or its lawyers. Prior results do not guarantee similar outcomes.

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