Prior to subsequent renewals, FinCEN will 1) analyze and provide a justification for adopting which methodology to employ in measuring aggregate burden, measuring by account or by entity; 2) disaggregate the burden estimate according to the four distinct requirements set forth in the regulation giving rise to the collection; 3) provide an explanation demonstrating the practical utility of each individual requirement; and 4) distinguish between the burdens associated with CIP for people vs. legal entities.
Inventory as of this Action
Requested
Previously Approved
11/30/2020
36 Months From Approved
04/30/2019
15,960
0
14,580
175,560
0
160,380
0
0
0
Banks, savings associations, credit unions, and certain non- federally regulated banks are required to develop and maintain customer identification programs. See 31 CFR 1020.100
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
0026 Banks etc CIP Supporting Statement 2018-11-21-18.docx
Customer identification programs for banks, savings associations, credit unions, and certain non-federally regulated banks.