Circular
Expanded Guidance on Customer Identification Program Rules Issued Pursuant to the USA PATRIOT Act
May 3, 2005
Circular No. 11702

To All Depository Institutions and Others  
    Concerned in the Second Federal Reserve District:

In a supervisory letter (SR-05-9) dated April 28, 2005, the federal bank, thrift regulatory bodies and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the Agencies) have released an expanded frequently asked questions documents (FAQs) to provide additional guidance on the customer identification program rules issued under section 326 of the USA PATRIOT Act. The expanded FAQs incorporate the FAQs previously released by the Agencies in 2004.

The expanded interpretive guidance addresses the applicability of the customer identification rules to data processing activities, to bank holding companies and their non-bank subsidiaries, and to subsidiaries of banks. The FAQs also provide additional guidance on the definitions of "account," "bank," and "customer."
 
SR letter (SR 05-9) OFFSITE 
FAQs OFFSITE PDF


Contacts:
Nicholas Farco
Examining Officer
Legal and Compliance Risk Department
nicholas.farco@ny.frb.org

Robert A. Otero
Examining Officer
Legal and Compliance Risk Department
robert.otero@ny.frb.org

William L. Rutledge
Executive Vice President