CIP rule should not be amended to allow for partial SSN collection

by America's Credit Unions

America’s Credit Unions opposes a change to the Customer Identification Program (CIP) rule to allow the partial collection of a social security number (SSN) for identity verification purposes.  Credit union concerns are outlined in a comment letter to the Financial Crimes Enforcement Network (FinCEN) sent Tuesday, in response to FinCEN’s request for comments related to the Taxpayer Identification Number (TIN) collection requirement under the CIP rule.

At issue is the potential access to consumers’ full SSN by a third party. The existing rule requires financial institutions to implement a written CIP that includes identity verification procedures, and financial institutions must currently collect a full SSN from a customer to fulfill the TIN requirement. FinCEN seeks input on the rule’s SSN collection requirement, including potentially allowing financial institutions to collect a partial SSN from the customer and then using a third-party to collect the full SSN.

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