April 2023 letter from AFC to FinCEN led to 2024 formal agency request for information (RFI).

"We applaud Acting Chairman Hill for recognizing the urgent need to modernize Customer Identification Program (CIP) requirements to align with today’s financial services landscape. AFC has been a vocal leader on CIP modernization and has long advocated for pragmatic regulatory updates that foster both consumer protection and responsible innovation."

"Our message to FinCEN has been clear: the CIP rule, as currently interpreted, is inconsistent with modern digital banking practices. Existing requirements create unnecessary friction for consumers without enhancing security. Allowing fintech companies and partner banks to collect only the last four digits of a Tax Identification Number (TIN) and verify the rest through trusted third-party sources is a long-overdue regulatory update that will enhance both security and financial inclusion. As Acting Chairman Hill rightly pointed out, banks have long been permitted to onboard credit card customers using this approach. Extending this flexibility to fintech-powered services is important to maintaining fairness in the industry and aligns the application of the CIP rule to the intent of its underlying statute."

"Modernizing the CIP rule will streamline account opening processes, promote financial access for all communities, and maintain robust identity verification standards that already protect consumers. We urge FinCEN to move swiftly toward formal rulemaking that codifies this common-sense update.”

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