Customer Identification Programs for Banks

ICR 202010-1506-005

OMB: 1506-0026

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2020-10-05
IC Document Collections
IC ID
Document
Title
Status
15332
Modified
ICR Details
1506-0026 202010-1506-005
Active 201808-1506-009
TREAS/FINCEN
Customer Identification Programs for Banks
Revision of a currently approved collection   No
Regular
Approved without change 10/08/2020
Retrieve Notice of Action (NOA) 10/08/2020
  Inventory as of this Action Requested Previously Approved
10/31/2023 36 Months From Approved 11/30/2020
16,001 0 15,960
178,205 0 175,560
0 0 0

Section 326 of the USA PATRIOT Act added subsection (l) to 31 U.S.C. 5318 of the BSA. Pursuant to section 326, FinCEN issued joint regulations with the federal bank regulatory agencies that require banks, savings associations, credit unions, and certain non-federally regulated banks to establish a written customer identification program and to maintain records related to verifying the identity of customers. Under the customer identification program (“CIP”) regulations, the minimum requirements include: 1) implementation of a written customer identification program appropriate for the financial institution’s size and type of business; 2) identity verification procedures; 3) recordkeeping; 4) comparison with government lists; and 5) customer notice. On September 14, 2020, FinCEN issued a final rule implementing sections 352, 326 and 312 of the USA PATRIOT Act and removing the anti-money laundering (“AML”) program exemption for banks that lack a Federal functional regulator, including, but not limited to, private banks, non-federally insured credit unions, and certain trust companies (the “Final Rule”). The Final Rule requires minimum standards for AML programs for banks without a Federal functional regulator to ensure that all banks, regardless of whether they are subject to Federal regulation and oversight, are required to establish and implement AML programs, and extends CIP requirements and beneficial ownership requirements to those banks not already subject to these requirements.

US Code: 31 USC 5318 Name of Law: Money and Finance
  
None

1506-AB28 Final or interim final rulemaking 85 FR 57129 09/15/2020

Yes

1
IC Title Form No. Form Name
Customer identification programs for banks

  Total Approved Previously Approved Change Due to New Statute Change Due to Agency Discretion Change Due to Adjustment in Estimate Change Due to Potential Violation of the PRA
Annual Number of Responses 16,001 15,960 0 41 0 0
Annual Time Burden (Hours) 178,205 175,560 0 2,645 0 0
Annual Cost Burden (Dollars) 0 0 0 0 0 0
Yes
Changing Regulations
No
FinCEN is requesting a revision of the information collection associated with regulations covering the CIP requirements. FinCEN is issuing this statement to support of the request for OMB approval of an information collection with respect to the final rule that will require certain banks that lack a Federal functional regulator to comply with the CIP requirements, among other things. This statement adds the estimated burden hours increase for this OMB control number, as a result of the final rule. The increase in burden hours is being added to the existing OMB approved burden hours for this control number as reflected in this supporting statement. On September 14, 2020, FinCEN issued a final rule implementing sections 352, 326 and 312 of the USA PATRIOT Act and removing the anti-money laundering (“AML”) program exemption for banks that lack a Federal functional regulator, including, but not limited to, private banks, non-federally insured credit unions, and certain trust companies (the “Final Rule”). The Final Rule requires minimum standards for AML programs for banks without a Federal functional regulator to ensure that all banks, regardless of whether they are subject to Federal regulation and oversight, are required to establish and implement AML programs, and extends CIP requirements and beneficial ownership requirements to those banks not already subject to these requirements.

$0
No
    No
    No
No
No
No
No
FinCEN Resource Center 800 767-2825 [email protected]

  No

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
 
 
 
 
 
 
 
    (i) Why the information is being collected;
    (ii) Use of information;
    (iii) Burden estimate;
    (iv) Nature of response (voluntary, required for a benefit, or mandatory);
    (v) Nature and extent of confidentiality; and
    (vi) Need to display currently valid OMB control number;
 
 
 
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
10/06/2020


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