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Federal Banking Agencies Issue Expanded FAQs on Customer Identification Programs

Friday, July 1, 2005

Federal banking agencies have released an expanded frequently asked questions document (FAQs) that provides additional guidance on the customer identification program (CIP) rules issued under Section 326 of the Patriot Act. The expanded interpretive guidance addresses how banks, savings associations, credit unions and certain non-federally regulated banks must apply customer identification rules when opening and maintaining customer accounts, processing customer data and engaging in other record-keeping activities. The FAQs also provide additional guidance on the definitions of "account," "bank" and "customer."

The agencies recognize that these expanded FAQs will not answer every question financial institutions may have, and the agencies encourage institutions to use the basic principles set forth in the CIP rule. Additionally, financial institutions must create risk-based procedures in their CIPs, which verify each customer's identity to a reasonable and practical extent.

The expanded FAQs can be found on the Board of Governors' web site, For more information about the FAQs, contact Jeff Bock at (314) 444-8835 or toll free at 1-800-333-0810, ext. 44-8835. To understand how banks can help combat identity theft and fraud, read Julie Stackhouse's Feditorial.