BPI submitted a letter to FinCEN responding to its proposal to renew without change Customer Identification Program (CIP) requirements, established under Section 326 of the Patriot Act, for banks and other financial institutions. In its letter, BPI stressed that FinCEN’s review is an opportunity to modernize key aspects of the CIP rule, arguing that (i) due to the rapidly changing technological landscape, the rule should be revised to take advantage of current and future innovations in customer identification, including innovations that allow firms to collect customer information from a broader range of secure and reliable sources; (ii) considerations that informed the statutory requirement and its 2003 implementing regulation, including consumer privacy and reliance on third parties, remain relevant today and demonstrate the need for flexible CIP programs; and (iii) the proposal underestimates the actual information collection burden.
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