Discover why implementing a robust customer identification program (CIP) helps your financial institution ensure regulatory compliance and enhance customer trust.
Whether you’re a large multinational bank or a local community credit union, all financial institutions have one thing in common: they must have a clear picture of who they are doing business with. Established by laws such as the Bank Secrecy Act and USA Patriot Act, this key mandate is designed to help spot and prevent instances of money laundering, fraud, the financing of terrorism, and other financial crimes. The procedures that financial institutions establish and follow to comply with these requirements are broadly known as Know Your Customer.
One key component of KYC is the customer identification program. It used to be a relatively straightforward process, but, with each passing year, it’s become increasingly difficult to manage, thanks to the rapid pace of change in the digital world. These difficulties only magnify the importance of CIPs today and how they may adapt to meet the demands of tomorrow.
So, let’s take a closer look at what a customer identification program is and how it works. Starting with the fundamentals, we’ll discuss the requirements that all CIPs must meet to ensure institutions like yours are well-equipped to protect your customers’ data and maintain your bank or credit union’s reputation.
What is a Customer Identification Program?
A CIP is a set of procedures that all banks and credit unions must establish and follow to verify the identity of their customers and users. Any business considered a financial institution under the Bank Secrecy Act and related laws must establish a customer identification program.
Although we will explore CIP requirements in greater depth later, it is essential for all CIPs to gather four critical pieces of information from the customer: their name, address, date of birth, and a government-issued identification number. Following this, the program requirements are clear but leave some room for flexibility.
CIP vs. KYC: What’s the Difference?
Although the terms are often used interchangeably, they are not the same. Know Your Customer protects financial institutions from fraud, corruption, money laundering, and terrorist financing. CIPs are just one component—albeit a very important one—of the KYC program. More specifically:
Customer Identification Program: A legal requirement outlined in the USA Patriot Act, a CIP is used to verify the information provided by the user so that financial institutions have a reasonable belief that they know their users’ true identities.
Know Your Customer: A specific process financial institutions use to verify a user’s identity and understand their business activities before engaging.
Additionally, KYC mandates are broader and involve more comprehensive due diligence procedures to assess and understand customer risk profiles. Other crucial parts of a KYC program that do not fall under the CIP umbrella include customer due diligence and continuous monitoring:
- Customer due diligence is a set of processes designed to evaluate the level of risk associated with a customer. A simplified due diligence process can be employed in lower-risk cases. However, situations with a higher risk may necessitate an enhanced due diligence (EDD) process. The EDD process involves additional scrutiny and investigation to ensure a thorough risk assessment.
- Continuous monitoring involves the consistent and ongoing surveillance of individuals and their transactions to identify suspicious activity. Any detected suspicious activity must be reported to the Financial Crimes Enforcement Network (FinCEN) and other relevant regulatory bodies as required.
What Are the CIP Requirements?
All customer identification programs are mandated to adhere to six general requirements outlined in the CIP Final Rule as established in the USA Patriot Act. These requirements are the foundation for implementing a robust and compliant CIP.
- Establishing a documented CIP: For any bank or credit union subject to the CIP rule, it isn’t enough to simply have a customer identification program. The program must also be written and dispersed amongst all employees who may play a role in the process.
- Collecting four specific pieces of identifying information: While the program requires collecting the customer’s name, address, date of birth, and government-issued identification number, those aren’t the only information that can be collected. Phone numbers and email addresses are, for example, commonly collected because they serve a role in customer communications.
- Establishing identity verification procedures: Financial institutions must employ reasonable processes to accurately identify and verify the identity of individuals seeking to establish an account. However, the CIP rule requires that the identity of all new customers be verified, but it does not specify how one needs to verify them. Verification can take several forms, such as documentary (upload official documents), database (compare info against other government databases), or biometric (using a person’s physical traits).
- Recordkeeping: Institutions must maintain records of customer identification information, including copies of identification documents and any additional information used to verify customer identity. A bank or credit union must retain this information for as long as the individual has an account with its business, plus five years from when the account closes or becomes dormant.
- Screening against government lists: Banks and credit unions must cross-check customer information—such as name, date of birth, and Social Security Number—against relevant government databases to detect any matches or discrepancies.
- Providing customers with notice: Finally, financial institutions must provide customers with proper and timely notice about the requirement to submit information, documentation, and any other necessary materials to verify their identities. This notice ensures transparency and allows customers to understand the purpose and necessity of the identity verification process.
However, the CIP Final Rule does not impose specific, rigid rules beyond the stated requirements. Meaning, as long as your bank or credit union fulfills these six requirements, you have considerable flexibility in tailoring your CIP to meet your needs and circumstances.
Why CIPs Really Matter
Customer identification programs are not just essential for regulatory compliance and risk mitigation—they also enhance customer trust and security. In an increasingly digital and interconnected world, customers are more concerned than ever about the security and privacy of their personal and financial information.
By implementing thorough identity verification processes, banks and credit unions demonstrate their commitment to protecting customer data and reducing the risk of identity theft or fraud. This commitment builds trust and fosters a sense of security among customers, which is fundamental for maintaining long-lasting relationships.
When customers are confident that their identities are verified, and their transactions are secure, they are more likely to engage in financial activities and maintain a positive relationship with their chosen financial institutions.
Customer Identification Programs Made Easier
At Lumin Digital, ensuring the highest level of security for all our financial institution partners is our utmost priority, starting with a robust customer identification program. As a cloud-native platform, our security protocols are already integrated into and running on multiple layers, providing you and your users with the latest and greatest digital protections. To learn more about how we can illuminate your institution’s success, contact us today.
