TIP: America’s Credit Unions says that a number of credit unions have asked them about:
- The presence of U.S. Immigration and Customs Enforcement (ICE) and whether they can be restricted if those officials attempt to enter the credit union’s premises, including branch locations and attendant parking lots; and
- Whether and under what circumstances the credit union can share the financial records of members who have used an Individual Taxpayer Identification Number (ITIN) as their method to confirm personal identity through the Customer Identification Program (CIP) process.
America’s Credit Unions has prepared an analysis of these questions, titled “Primer on Potential ICE Encounters Onsite at Credit Unions,” which its members can download via their Compliance Community.
Credit unions should pay attention to the important disclaimer at the top of the guidance.
America’s Credit Unions says that it will continue to update the guidance as questions come up. Please reach out to them directly if you have questions or if other issues arise that might be added to the document.