WASHINGTON–The Financial Crimes Enforcement Network (FinCEN) has some questions about collecting Social Security numbers (SSNs) and it is seeking feedback.
FinCEN has published a request for information (RFI) in the Federal Register that proposes revisions to its customer identification program (CIP) rule under the Bank Secrecy Act (BSA). In this case, it would permit financial institutions to collect just part of an individual’s Social Security number, instead of the full SSN, prior to account opening. Such partial collection is currently permitted for credit cards alone.
In its notice, FinCEN said pointed to some of the practical reasoning behind the current exception for credit cards, noting that customers often open credit card accounts at the point of sale. It also includes similar discussion regarding buy now, pay later programs that extend credit at the point of sale.
NCUA Also Consulted
FinCEN said its RFI – issued in consultation staff at the Office of the Comptroller of the Currency (OCC), the FDIC, the NCUA and the Federal Reserve– seeks information and comment on the potential risks, benefits, and safeguards around banks collecting partial SSNs for U.S. individuals directly from the customer “and subsequently using reputable third-party sources to obtain a full SSN prior to account opening.” It said it is also gathering information about current industry practices regarding SSN collection.
“To allow FinCEN to evaluate comments more effectively, FinCEN requests that, where possible, comments include any suggested use of FinCEN authorities, or changes to FinCEN regulations or guidance, including the nature of the requested change and supporting data or other information on impacts, costs, and benefits,” FinCEN said.
Where Input is Being Sought
Among the topics on which it is seeking input:
- What types of safeguards would be needed if such a change to the CIP rule were implemented?
- Related practices and procedures
- Due diligence
- The effect of the current requirement to collect the full SSN from a customer at account opening (including on a bank’s anti-money laundering, or AML, program).
- Whether FIs should be permitted to collect other customer identifying information from a third-party source.
The draft notice says comments will be due 60 days from publication in the Register.
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