Customer Identification Programs for Broker-Dealers

Forms and Documents

Document Name	Status
0034 BD CIP Supplemental Statement 20201125 Final.docx Supporting Statement A	2020-11-25

IC Document Collections

IC ID	Document Title	Status
15345	Customer Identification Programs for Broker-Dealers	Modified

ICR Details

OMB Control No: 1506-0034	ICR Reference No: 202011-1506-005
Status: Received in OIRA	Previous ICR Reference No: 201808-1506-011
Agency/Subagency: TREAS/FINCEN	Agency Tracking No:
Title: Customer Identification Programs for Broker-Dealers
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 11/30/2020

	Requested	Previously Approved
Expiration Date	36 Months From Approved	01/31/2021
Responses	9,000,000	9,000,000
Time Burden (Hours)	340,040	300,000
Cost Burden (Dollars)	0	0

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Abstract: 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 Securities and Exchange Commission that require broker or dealers in securities 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.

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Authorizing Statute(s): US Code: 31 USC 5318 Name of Law: Money and Finance
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 49425	08/13/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 75408	11/25/2020
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Customer Identification Programs for Broker-Dealers

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ICR Summary of Burden

	Total Request	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	9,000,000	9,000,000	0	0	0	0
Annual Time Burden (Hours)	340,040	300,000	0	0	40,040	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The estimated total annual burden hours increased from 300,000 hours since the last control number renewal in 2018 to 340,040 hours. The estimated number of new accounts opened per year remained at 9,000,000 with an estimate of 2 minutes per account to collect CIP information. The increase in burden is a result of the burden estimate of 10 hours per broker or dealer in securities to update and maintain the CIP, and one hour per broker or dealer in securities to provide customers with notification of the CIP requirements, despite the reduction in the number of brokers or dealers in securities from 3,839 in 2018 to 3,640, based on 2020 data.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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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:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(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;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

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.

Certification Date: 11/30/2020

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