The Office of the Comptroller of the Currency (OCC), jointly with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration, issued answers to frequently asked questions (FAQ) related to the use of state-issued mobile driver's licenses and other government-issued verifiable digital credentials (VDC). The answers to these FAQs clarify how banks may use such VDCs to comply with the Customer Information Program (CIP) Rule. This matters because the CIP Rule, codified at 31 CFR 1020.220, is a foundational anti-money-laundering obligation under the Bank Secrecy Act, and the new guidance gives regulated institutions a clearer path to accept digital identity documents without running afoul of existing compliance expectations.
The FAQs address specific topics related to the treatment of VDCs under the CIP Rule, though the bulletin itself does not enumerate the individual questions in the publicly available text. The guidance is applicable to all community banks, which the OCC defines in a related news release as institutions with up to $30 billion in assets. The bulletin was issued on September 8, 2026, and references an earlier OCC News Release dated September 18, 2025, indicating that the regulatory conversation around digital identity and community bank applicability has been developing for at least a year. The term "banks" in the bulletin refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.
The primary source for this development is OCC Bulletin 2026-44, published directly by the OCC on its official website. The bulletin is signed by James M. Gallagher, Senior Deputy Comptroller and Chief National Bank Examiner, and directs interested parties to contact the Compliance and Operational Risk Division, Office of the Chief National Bank Examiner, at (202) 649-6550. The document is a tier-one primary source, meaning it carries the full authority of the issuing agencies. However, the publicly available text is relatively brief, and the specific FAQ answers themselves are not reproduced in the bulletin, limiting the depth of analysis that can be drawn from this single document alone.
For banks and credit unions, the practical implication is that state-issued mobile driver's licenses and other government-issued VDCs may now be treated as acceptable forms of identification under the CIP Rule, subject to the conditions described in the FAQs. This could reduce friction in digital account opening and remote customer onboarding, particularly for community banks that may lack the resources to build proprietary identity verification systems. The joint nature of the guidance—spanning the OCC, FinCEN, the Federal Reserve, the FDIC, and the NCUA—signals a coordinated interagency position, which reduces the risk of conflicting supervisory expectations across different charter types. Still, the bulletin does not provide details on technical standards, security requirements, or liability allocation, and those specifics likely reside in the full FAQ document that is not included in the source text.
What to watch next is whether the agencies publish the complete FAQ text or additional implementation guidance, and whether state motor vehicle agencies accelerate issuance of mobile driver's licenses in response to this regulatory clarity. The bulletin's reference to a September 2025 news release also suggests that the OCC has been signaling its community bank definition and digital identity priorities for some time, but the source does not indicate whether further rulemaking or legislative action is contemplated. Until the full FAQ content is available, banks should treat the bulletin as a directional signal rather than a complete compliance manual.