In a supervisory letter published Tuesday (Aug. 5), the agency clarified that pre‑populating onboarding forms with data pulled from existing customer files, affiliates or trusted vendors can satisfy Customer Identification Program (CIP) requirements under Section 326 of the USA PATRIOT Act.
The guidance stressed that the CIP rule’s mandate to collect identifying information “from the customer” does not prohibit autofill flows so long as the customer ultimately reviews and submits the data. The interpretation applies to all FDIC‑supervised institutions and is expected to accelerate friction‑light account opening while reducing abandonment and fraud.
According to the FDIC, examiners will consider pre‑filled data to be customer‑provided if two guardrails are present: (1) applicants can review, correct and confirm the entries, and (2) the bank’s risk‑based procedures still support a reasonable belief in the customer’s true identity, mitigating synthetic‑ID and takeover risk.
Acceptable autofill sources now explicitly include parent organizations, FinTech partners and other third parties, giving banks more levers to reuse verified identity attributes across product lines.
The update arrives amid soaring consumer expectations for instant onboarding and intense competitive pressure from neobanks already leveraging pre‑population to capture deposits. While the approach relaxes one hurdle, it underscores that institutions remain accountable for AML/KYC controls proportional to their risk profile.
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“It is the FDIC’s position that the requirement to collect identifying information ‘from the customer’ under the CIP rule does not preclude the use of pre‑filled information,” the guidance stated.
PYMNTS has consistently covered the need for less friction in the account opening and verification process. Bank account and payment intelligence firm ValidiFI began offering new bank account verification capabilities in April, as part of an expansion of the company’s vAccount+ suite, designed to give companies greater coverage and accuracy when conducting account verifications.
The company’s release at the time noted that ValidiFI’s data network includes access to J.P. Morgan Payments’ validation services and Early Warning, which contains deposit performance data from more than 2,500 financial institutions, banking giants such as Wells Fargo and Bank of America among them.
“This provides our clients with frictionless, highly reliable validation to minimize false declines for legitimate customers, reduce payment returns, and lower the administrative burden of manual reviews,” the release added. “The result is a more efficient process that builds trust, enhances customer experience and streamlines payment operations.”
