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)
FAQs
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