WASHINGTON,, DC (June 27, 2025) |
The Defense Credit Union Council (DCUC) announces its strong support for the joint agency exemption order issued June 25, 2025, by the National Credit Union Administration (NCUA) alongside fellow regulators.
This interagency order grants relief from a key Customer Identification Program (CIP) requirement under Section 326 of the USA PATRIOT Act, allowing credit unions and banks to obtain a member’s Taxpayer Identification Number (TIN) through an alternative collection method from a trusted third-party source, rather than directly from the customer, provided certain conditions are met. DCUC applauds the NCUA, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Financial Crimes Enforcement Network (FinCEN) for this collaborative effort to modernize regulations in a way that upholds security while improving service to members.
Supporting Military Members and Their Families
As the leading voice for credit unions serving those who serve our country, DCUC believes this exemption order will greatly benefit military service members and their families.
Since the CIP rule’s initial adoption in 2003, financial services have evolved and consumers have grown more reluctant to provide their full Social Security numbers or TINs due to pervasive data breaches and identity theft concerns. These concerns are often pronounced in the military community, where operational security and personal privacy are paramount. By permitting financial institutions to securely retrieve necessary identification data from reputable third-party databases instead of requiring members to directly divulge sensitive information, regulators have provided much-needed flexibility to improve the member experience.
This change does not dilute the rigor of identity verification – banks and credit unions must still employ risk-based CIP procedures to form a reasonable belief of each customer’s true identity. In short, the order offers a new avenue to meet CIP obligations without putting an added burden on members who may be uncomfortable sharing personal identifiers, especially through electronic channels.
Compliance Relief for Defense Credit Unions
DCUC welcomes this targeted compliance relief, noting that it is entirely optional for credit unions to adopt. By eliminating a one-size-fits-all mandate and allowing an alternative TIN collection method, the agencies are empowering each institution to choose the approach that best fits its mission and membership. This flexibility is especially valuable for defense credit unions, which often operate on military installations worldwide and serve a mobile, deployed clientele. Every dollar diverted to redundant compliance costs is a dollar not spent on military community programs, better rates, or improved services for service members and their families.
Regulatory improvements like the CIP exemption help ensure that resources can be redirected from paperwork to people – enhancing the financial well-being of those who wear our nation’s uniform. DCUC has long advocated for common-sense regulatory right-sizing, and this order is a prime example of smart relief that upholds safety and soundness while easing unnecessary administrative burdens.
Advocating Member Access and Experience
DCUC also emphasizes that this modernization will directly improve member access to financial services and the overall banking experience. By embracing innovative identity verification tools, defense credit unions can expand online and mobile banking capabilities to better serve members stationed around the globe. For example, a newly enlisted service member or a military spouse will find it easier to open an account or apply for a loan remotely without the friction of submitting a full TIN through potentially insecure means.
Regulators themselves have highlighted that this exemption promotes financial inclusion by addressing the legitimate concerns of customers unwilling to provide their full TIN electronically, thereby allowing greater access to accounts and credit. In practical terms, military families – who frequently relocate or deploy – will enjoy faster, more convenient account opening and verification processes that maintain robust security without sacrificing convenience. DCUC sees this as a win-win: reducing barriers for members while preserving strong anti-fraud protections.
Member-Centered Benefits for the Military Community
This exemption is particularly meaningful for credit unions serving the armed forces community. Defense credit unions exist solely to support the financial readiness of military personnel and veterans, and any measure that helps them better fulfill this mission is wholeheartedly welcomed.
“Credit unions, especially those serving our military community, are vital to financial readiness and inclusion,” says Jason Stverak, DCUC’s Chief Advocacy Officer.
DCUC has consistently urged policymakers to preserve the “tools and protections” that allow credit unions to continue their mission. We believe this CIP rule change is precisely such a tool – a prudent adjustment that enables credit unions to leverage modern technology and data resources to serve members more efficiently, without compromising the integrity of required security measures. From enabling quicker account access for a deployed airman, to simplifying identity confirmation for a veteran opening a new account from home, the benefits of this order will be felt broadly across the military community.
DCUC commends the NCUA and its partner agencies for recognizing the unique needs of credit unions and their members in today’s digital age. This action reflects a balanced approach to regulation: it eases regulatory burden and gives institutions choice in how they comply,
all while maintaining the strict anti-money laundering standards that protect our financial system.
“We are grateful for the regulators’ responsiveness and collaboration in delivering this common sense reform. DCUC and our member credit unions remain fully committed to safeguarding the financial security of our communities – and thanks to this exemption, we can do so with even greater efficiency and member-focus,” said Anthony Hernandez, DCUC President/CEO. “We look forward to working with NCUA and the other agencies to implement this change and continue ensuring that our nation’s heroes and their families receive the best possible access to safe, affordable financial services.”