When you apply for a credit card, you’re often only asked for the last four digits of your Social Security number. The issuer fills in the rest by verifying your information with a trusted third party like a credit bureau.
This model, in place for years in the credit card industry, allows for faster onboarding and less friction for customers. Now, thanks to a recent change from the OCC, FDIC, and NCUA, banks and credit unions can use a similar approach for nearly all account types.
The new exemption to the Customer Identification Program (CIP) Rule allows supervised banks and credit unions to collect a taxpayer identification number (TIN) from a trusted third-party source rather than directly from the customer, as long as all other CIP requirements for risk-based identity verification are met.
The FDIC explained:
“This order permits banks… to use an alternative collection method to obtain TIN information from a third-party rather than from the customer… enabling the bank to form a reasonable belief that it knows the true identity of each customer.”
It’s a move designed to reduce friction, modernize onboarding, and reduce cybersecurity exposure from storing full SSNs — but it also changes the fraud risk landscape.
Credit card issuers have lived with this reduced-data onboarding for years, and they’ve made it work through a combination of:
This layered, connected approach offsets the risk of not collecting the full SSN directly.
For deposit accounts, the CIP exemption removes a key barrier in onboarding, but it also accelerates the speed at which fraudsters can test stolen or synthetic identities across multiple institutions.
Credit card issuers have the advantage of long-standing consortium intelligence. Many banks and credit unions don’t. That’s where FiVerity comes in.
FiVerity’s Anti-Fraud Collaboration Platform consolidates account intelligence from across participating institutions - uniting account details, fraud signals, and investigative insights in a single view. This shared visibility helps fraud and AML teams:
The result: institutions can embrace faster onboarding without opening the door wider to fraud.
The CIP exemption is a big win for customer experience, but only if fraud teams are equipped to keep pace. Credit card issuers have shown it’s possible to balance speed and security, but only through connected intelligence, real-time detection, and coordinated response.
With this regulatory shift, the opportunity is clear: modernize onboarding, strengthen defenses, and close the gaps fraudsters exploit.