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OCC Bulletin 2020-88 | October 9, 2020

Bank Secrecy Act/Anti-Money Laundering: Revised Order Granting Exemption From Customer Identification Program Requirements for Premium Finance Lending


Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively, the agencies), with the concurrence of the Financial Crimes Enforcement Network (FinCEN), today issued a revised order granting an exemption from the requirements of the customer identification program rules implementing section 326 of the USA PATRIOT Act for certain loans. The affected loans are those extended by banks1 and their subsidiaries under the jurisdiction of the agencies to customers to facilitate purchases of property and casualty insurance policies referred to as insurance premium finance lending or premium finance loans. This revised order extends the customer identification program exemption for premium finance loans to all customers of banks.


This bulletin replaces OCC Bulletin 2018-35, "Bank Secrecy Act/Anti-Money Laundering: Order Granting Exemption from Customer Identification Program Requirements for Premium Finance Lending." The order conveyed under OCC Bulletin 2018-35 limited the exemption to commercial customers.

Note for Community Banks

The revised order applies to community banks.


The agencies have determined, and FinCEN has concurred, that granting this exemption from the requirements of the customer identification program rules is consistent with

  • the purposes of the Bank Secrecy Act.
  • safe and sound banking practices.

Further Information

Please contact James Vivenzio, Acting Director for BSA/AML Compliance Policy, at (202) 649-5470.


Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Link

1 For the OCC, "banks" refers collectively to national banks, federal savings associations, covered savings associations, and federal branches and agencies of foreign banking organizations.