Summary
The proposed PPSI CIP rules closely mirror the bank CIP model (31 CFR 1020.220) with three key differences: (1) the "account" definition includes stablecoin-specific carve-outs excluding secondary market activity and mere ownership of stablecoins without a formal relationship; (2) the "customer" definition excludes persons acquiring/redeeming stablecoins other than directly from/to the PPSI; and (3) reliance provisions allow PPSIs to rely on other federally regulated financial institutions' CIPs but create a one-directional gap for state-supervised issuers. The rules require name, DOB/formation date, physical address (no PO boxes), and identification number. Comments due August 21, 2026. 12-month implementation period proposed.
Key Points
- Modeled on bank CIP (31 CFR 1020.220) with stablecoin-specific modifications
- "Account" excludes secondary market activity and mere stablecoin ownership
- "Customer" excludes secondary market acquirers/redeemers
- Required info: name, DOB/formation date, physical address, ID number
- Reliance: only on federally regulated financial institutions (SQPSIs excluded as rely-ee)
- Joint rulemaking: FinCEN, OCC, Fed, FDIC, NCUA
- Comments due: August 21, 2026
- Implementation: 12 months after final rule
- Estimated 50 PPSIs in first 3 years
- Estimated annual cost: ~$2.3M aggregate across all PPSIs