0Acting FDIC Chairman Expresses Support for Enhancing Flexibility of Customer Identification Program Requirements
On February 7, the Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill sent a letter to the Financial Crimes Enforcement Network (FinCEN) in support of enhancing the flexibility of Customer Identification Program (CIP) requirements for bank-fintech partnerships – specifically, to allow fintechs to satisfy their CIP obligations by obtaining the last four digits of their customers’ social security or tax identification numbers and, with their customers’ permission, obtaining the rest of the number from a third-party source, such as a credit bureau. The Acting Chairman also requested that FinCEN work to align CIP requirements with the reality of bank-fintech relationships more broadly.
0FRB Releases the Hypothetical Scenarios for Its Annual Stress Test and Exploratory Analysis
On February 5, the Board of Governors of the Federal Reserve System (FRB) released the hypothetical scenarios for its annual stress test, as well as two hypothetical elements assessing a wider range of risks through its “exploratory analysis” of the banking system. The annual stress test evaluates the resilience of large banks under two-year hypothetical recession scenarios, helping ensure that large banks can lend to households and businesses even in severe economic downturns. The FRB will publish aggregate results of these tests in June 2025. The FRB also intends to begin the public comment process this year on comprehensive changes to the stress test to reduce volatility of results and improve model transparency.
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Editors
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Josh Burlingham
Associate - /en/people/k/kirby-samantha
Samantha M. Kirby
PartnerChair, Financial Services - /en/people/m/mccurdy-williamWM
William McCurdy
Senior Attorney
Contributors
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Nikki Cary
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Ana Valeanu
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