On 10/5/2020, the joint agencies (OCC, FDIC, NCUA, Federal Reserve, and FinCEN) issued an order to exempt CIP (customer identification program) requirements for loans extended by banks to facilitate purchases of property and casualty insurance policies. This order comes after a group of banks jointly submitted letters in 2016 and 2017 requesting an exemption or interpretation regarding the application of the CIP rules to insurance premium finance lending. These letters asserted that CIP was not needed for insurance premium finance lending because this activity presents a very low risk of money laundering because of the purpose for which the loans are extended and the limitations on the ability of a customer to use such funds for any other purpose. On 9/27/18, an initial exemption was granted by the joint agencies specifically for commercial customers. This new order extends the exemption to all customers, not just commercial customers.

The full order can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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