SR 25-2: Order Granting an Exemption from the Customer Identification Program Rule Requirement Related to a Bank Obtaining Taxpayer Identification Number Information from the Customer
Regulatory relief providing banks flexibility in TIN collection methods under Customer Identification Program requirements
Advisory Assessment
Impact. The Federal Reserve has granted banks discretionary authority to obtain taxpayer identification numbers from third-party sources rather than directly from customers, while preserving all other Customer Identification Program requirements. This regulatory relief allows institutions to streamline account opening processes and potentially reduce customer friction without compromising anti-money laundering compliance obligations.
Risk. The primary exposure lies in third-party risk management, where institutions adopting alternative TIN collection methods must ensure vendor reliability and data accuracy. Compliance teams face examination scrutiny around whether third-party TIN verification procedures maintain the same level of customer identity verification that direct collection provides.
Recommended Action. Compliance should conduct a cost-benefit analysis of current TIN collection processes versus third-party alternatives, focusing on operational efficiency gains and vendor risk trade-offs. If pursuing the exemption, establish clear vendor due diligence standards and accuracy thresholds for third-party TIN data before updating CIP policies.
Watch. Monitor examination guidance from the Federal Reserve and other banking agencies regarding expectations for third-party TIN collection oversight and quality control measures. Track industry adoption patterns to gauge competitive positioning and regulatory comfort levels with alternative verification methods.
Classification
- Regulatory Program
- Bank Secrecy Act - Customer Identification Program
- Doc Type
- Guidance
- Effective Date
- 2025-08-15
- Days to Action
- -335
- Comment Deadline
- —
- Published
- 2025-01-01
Urgency Basis
Effective date was August 15, 2025, which is over 180 days past as of reference date May 15, 2026. This is optional relief that banks can implement at their discretion.
Operational Context
Impact by Category
Key Requirements
Scoring Rationale
This is optional regulatory relief rather than a new obligation. The Federal Reserve is permitting banks to collect Taxpayer Identification Numbers from third-party sources instead of directly from customers, while maintaining all other CIP requirements. Impact is low across affected categories because: (1) compliance impact is limited since this provides flexibility rather than new requirements, (2) operational changes are optional and involve policy updates rather than system overhaul, (3) third-party risk increases modestly due to potential new vendor relationships for TIN collection. The exemption has been effective since August 2025 and represents a lessening of regulatory burden.