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FDIC updates approach to pre-filled customer information


The FDIC announced it is updating its supervisory approach regarding whether banks can use pre-populated customer information for the purpose of opening an account to satisfy Customer Identification Program requirements.

August 06, 2025 / By ICBA

The FDIC announced it is updating its supervisory approach regarding whether banks can use pre-populated customer information for the purpose of opening an account to satisfy Customer Identification Program requirements.

Details: In a new Financial Institution Letter, the FDIC said:

  • It is the FDIC’s position that the requirement to collect identifying information “from the customer” under the CIP rule does not preclude the use of pre-filled information.

  • Under its interpretation, a bank could use information from current or prior accounts or relationships involving the bank or its agents, or other sources, to pre-fill information that is reviewed and submitted by the customer.

More CIP News: The federal banking agencies recently permitted banks to obtain a Tax Identification Number from a third party rather than directly from customers under the CIP rule.

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