Client Alert – FDIC OCC NCUA Issue Exemption Order to CIP Rule Requirements

July 1, 2025

To our clients and friends:

On June 27, 2025, the FDIC, the OCC, and the NCUA issued an order (the “Order”) exempting their supervised institutions from the Customer Identification Program Rule’s requirement to obtain taxpayer identification numbers directly from customers at account opening, permitting them to instead obtain this information from a third-party source. The Order is a significant step forward in modernizing the Bank Secrecy Act and FinCEN’s anti-money laundering regulations. Our Alert covering the Order and key takeaways is available here.

Luse Gorman regularly advises financial institutions regarding compliance with the Bank Secrecy Act, USA PATRIOT Act, Anti-Money Laundering Act of 2020, and FinCEN’s anti-money laundering regulations. If you have any questions about this Alert, please contact the authors. To learn more about our firm and services, please visit our website.

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Luse Gorman is Legal Counsel to Community Bank, N.A. in its Proposed Acquisition of Seven Pennsylvania Branches from Santander Bank, N.A.

June 26, 2025

On June 24, 2025, Community Bank, N.A. (“Community Bank”), a subsidiary of Community Financial System, Inc., entered into a Purchase and Assumption Agreement with Santander Bank, N.A., to acquire seven branch locations in the Allentown, PA area. Under the agreement, Community Bank will assume approximately $600 million in deposits and purchase approximately $33 million in branch-related loans. In addition, Community Bank will purchase related wealth management relationships.

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