2024-19593. Agency Information Collection Activities; Submission for OMB Review; Comment Request; Customer Identification Program Regulatory Requirements for Certain Financial Institutions

Table 1—Distribution of Financial Institutions and New Accounts Covered by This Notice, by Type of Financial Institution

Type of financial institution	Number of financial institutions	Number of new accounts opened annually
0022 Futures commission merchants and introducing brokers in commodities	954	557,000
0026 Banks	10,400	53,615,000
0033 Mutual Funds	1,400	16,150,000
0034 Brokers-dealers	3,478	28,000,000
Total	16,232	98,322,000

In connection with a variety of initiatives FinCEN is undertaking to implement the AML Act, FinCEN intends to conduct, in the future, additional assessments of the PRA burden associated with BSA requirements.

Part 2. Annual PRA Burden and Cost

For all covered financial institutions, FinCEN continues estimating the incremental annual PRA recordkeeping burden associated with maintaining and updating the CIP (“maintenance”) at ten hours per financial institution. This estimate covers: (a) an average of approximately nine hours per financial institution per year associated with the burden of updating the records necessary to demonstrate compliance with CIP requirements to take into consideration any regulatory changes and any modifications required as a result of a financial institution making changes to the type of accounts maintained, the methods used to open accounts, and the types of documentary or nondocumentary methods for verifying identifying information the financial institution intends to use; and (b) an average of approximately one hour per financial institution associated with the burden of presenting the updated CIP to the appropriate level of management within the financial institution and obtaining approval.

In addition, FinCEN continues estimating the incremental annual PRA recordkeeping burden associated with providing customers with notification of the CIP (“notification”) at one hour per financial institution. FinCEN has increased the estimate of the incremental annual PRA recordkeeping burden associated with obtaining and verifying a customer's identity ( i.e., verification and recordkeeping requirements, and consulting government lists) (“implementation”) to three minutes per new account opened.

Under these assumptions, FinCEN's estimate of the annual incremental PRA burden is 5,094,652 hours, as detailed in tables 2 and 3.

Table 2—Incremental Annual Burden Associated With Updating and Maintaining the CIP and Customer Notification for All Covered Financial Institutions

Type of financial institution	Number of financial institutions	Time per financial institution		Burden hours per step		Total burden hours
		Maintenance (hours)	Notification (hour)	Maintenance	Notification
0022 Futures commission merchants and introducing brokers in commodities	954	10	1	9,540	954	10,494
0026 Banks	10,400	10	1	104,000	10,400	114,400
0033 Mutual Funds	1,400	10	1	14,000	1,400	15,400
0034 Brokers-dealers	3,478	10	1	34,780	3,478	38,258
Total	16,232			162,320	16,232	178,552

Table 3—Incremental Annual Burden Associated With Implementing the Identity Verification, Recordkeeping, and Consulting Government Lists Requirements for All Covered Financial Institutions

Type of financial institution	Number of financial institutions	New accounts opened per year	Time per new account (minutes)	Total burden in minutes	Total burden converted to hours
0022 Futures commission merchants and introducing brokers in commodities	954	557,000	3	1,671,000	27,850
( print page 70692)
0026 Banks	10,400	53,615,000	3	160,845,000	2,680,750
0033 Mutual Funds	1,400	16,150,000	3	48,450,000	807,500
0034 Brokers-dealers	3,478	28,000,000	3	84,000,000	1,400,000
Total	16,232	98,322,000		294,966,000	4,916,100

FinCEN is utilizing the same fully loaded composite hourly wage rate of $106.30 utilized in other OMB control number renewals and notices of proposed rulemakings (NPRMs) recently opened to public review and comment. The total estimated cost of the annual PRA burden is $541,561,508, as reflected in table 4 below:

Table 4—Total Cost of Annual PRA Burden

Task	Hours	Hourly cost	Total cost
Maintaining and updating the CIP (10 hours per FI)	162,320	$106.30	$17,254,616
Customer notification of CIP (1 hour per FI)	16,232	106.30	1,725,462
Implementing the CIP (identifying and verifying customer information, maintain records, and consulting government lists) (2 minutes per account	4,916,100	106.30	522,581,430
Total	5,094,652		$541,561,508