FDIC Clarifies Stance on Use of Pre-Populated Customer Data to Open Accounts

The Federal Deposit Insurance Corporation (FDIC) recently issued new supervisory guidance applicable to all FDIC-supervised institutions regarding the use of pre-populated customer data.

The new guidance provides that the use of pre-filled information, such as data found in electronic forms, meets Customer Identification Program (CIP) requirements under the USA PATRIOT Act, provided that (i) the customer has the opportunity and ability to review, correct, and confirm the accuracy of such pre-populated information, and (ii) the institution’s processes for opening an account that involves pre-populated information allow the institution to form a reasonable belief as to the identity of its customer, and are based on the institution’s assessment of the relevant risks, including the risk of fraudulent account opening or takeover.