On September 8, 2026, FinCEN and the staffs of the Federal Reserve, the FDIC, the NCUA, and the OCC issued two new FAQs under the Customer Identification Program Rule plus an amendment to a third.
Federal Regulators Clear mDLs for Bank Onboarding | Trinsic ↗
What happened
- The FAQs state that an unexpired government-issued VDC can qualify as government-issued identification under 31 C.F.R. § 1020.220(a)(2)(ii)(A)(1) if it evidences nationality or residence and bears a photograph or similar safeguard.
- The amended FAQ covers using an electronic credential, digital certificate, or VDC as a non-documentary means of verification.
- For credentials issued by a non-government third party, the bank remains responsible for ensuring the third party uses the same level of authentication the bank would use, measured against FFIEC guidance.
- Trinsic describes itself as digital ID acceptance infrastructure accepting mDLs, government eIDs, private reusable IDs, EUDI wallets and verifiable credentials through one integration.
Why it matters to Signicat
- Regulatory reading of the FAQs favors wallet-based credentials in bank CIP, a route adjacent to Signicat's Wallet Hub and document/NFC onboarding.
- Trinsic's positioning as a single acceptance layer for many digital IDs competes with Signicat's eID and Wallet Hub orchestration narrative.
Evidence from the source (6 quotes)
- “An unexpired, government-issued VDC qualifies as a "government-issued identification" under 31 C.F.R. § 1020.220(a)(2)(ii)(A)(1), provided it also evidences nationality or residence and bears a photograph or similar safeguard.” source ↗
- “The amended FAQ covers using an electronic credential, a digital certificate, or a VDC as a non-documentary means of verification, and it now says "verifiable digital credential" out loud.” source ↗
- “For credentials issued and maintained by a non-government third party, the bank or credit union is responsible for ensuring that the third party uses the same level of authentication as the bank or credit union itself would use, measured against the FFIEC guidance on authentication in an electronic banking environment.” source ↗
- “Trinsic is digital ID acceptance infrastructure. Through one integration you accept the digital IDs your customers already carry, including mobile driver's licenses, government eIDs, private reusable IDs, EUDI wallets, and verifiable credentials, across many providers and countries.” source ↗
- “That puts an mDL in the same bucket as a passport or a physical driver's license, which is the friendliest outcome available: no new category, no bespoke risk framework, nothing to wait for.” source ↗
- “Through one integration you accept the digital IDs your customers already carry” source ↗
Reusable identity VCEUDI wallet eIDAS 2AML KYB screeningOrchestration platformPositioning narrativeRegulatory commentaryThought leadershipGlobal
5 of 5 facts verified against the source · confidence high · claude-haiku-5-5