A federally observed pilot launched this summer could reshape how financial institutions verify customers, replacing repetitive identity checks with a portable, reusable verification model that lets consumers carry trusted credentials from one institution to the next.
The SOLO Network, a consumer reporting agency, announced the pilot in coordination with the Treasury Department, the Financial Crimes Enforcement Network, the Office of the Comptroller of the Currency and the FDIC. SOLO says the effort, which began June 8, is the first coordinated engagement across all four bodies aimed at making bank-to-bank reliance work at scale. The company compares the concept to TSA PreCheck: a customer whose identity documents, biometrics and liveness checks were verified at one regulated institution could authorize another to evaluate that completed work rather than starting over.
The legal foundation is not new. Since 2003, the Customer Identification Program rule has permitted a bank to rely on verification performed by another federally regulated institution, provided the reliance is reasonable and backed by a contract and annual anti-money laundering certification. In practice, differences in bank policies have confined reliance to affiliate and sponsor-bank arrangements. SOLO aims to close that gap with standardized certificates documenting what work was performed, by which methods, when and by whom. A receiving bank sets its own policy requirements; if no qualifying certificate exists, it performs the missing steps itself.
Notably, SOLO says regulators identified NIST Identity Assurance Level 2 as the benchmark for evaluating verification completeness, a signal that federal assurance standards may become the common language for portable identity in financial services.
The certificates carry defined limits. They cannot be used to decline an applicant, they exclude sanctions and OFAC screening, and reliance does not relieve a bank of customer due diligence, transaction monitoring or suspicious activity reporting duties. SOLO acknowledges that regulatory observation is not a no-action letter, safe harbor or endorsement, and as of Aug. 11 none of the four agencies had issued a companion announcement.
SOLO reports its network includes 10 sponsor banks and more than 240 fintech programs representing over 100 million consumer and small-business profiles, figures that describe network coverage rather than pilot participation. Former CFPB Acting Director Mick Mulvaney has advised the company since October 2025.
