What's the Dilly-o with consumer identity verification (KYC): a buyer's guide for credit unions
U.S. lenders lost a record $3.2 billion to synthetic identity fraud in 2024.1 Then in September 2026, the Financial Crimes Enforcement Network (FinCEN) explained how a credit union may accept a state mobile driver's license (mDL) under its existing customer identification program (CIP).2 So we'd ask two things of the tool that checks your new members: can it stop identities that never existed, and can it read an ID on a phone?
The Dilly-o
Synthetic identities can get past traditional identity checks and run for months before they default.3 We'd start by checking what your account opening platform already includes, then test any vendor on deepfake resistance and digital ID readiness before you sign. We'd also get each vendor's answer on mDLs in writing.
How we'd size up a vendor
- Document and selfie match - ask whether the tool verifies a government ID and matches it to a live selfie.
- Deepfake resistance matters because criminals can use deepfakes to pass video verification during account opening.3 Ask for test results from outside the vendor, not just its own claims.
- Digital ID readiness - can the tool read and extract the data from a verifiable digital credential such as an mDL? FinCEN's FAQs say a credit union that accepts these credentials needs technology that can extract the relevant information.2
- Fit with your account opening - does the tool already connect to your digital banking platform, account opening system and core? A listed integration saves months; a custom build adds cost and risk.
What changed this year
In September 2026, FinCEN's FAQs said a credit union may accept an unexpired government-issued verifiable digital credential if it meets the CIP documentary criteria and its CIP allows it.2 The FAQs create no new rule and do not make mDLs mandatory.4 Nacha's fraud monitoring rule took practical effect on June 22, 2026.5 Its definition of false pretenses covers payments induced by misrepresenting identity, authority or account ownership.6
Will it work with your systems?
We've verified that MANTL and Onfido (Entrust) are both listed for Symitar credit unions on Jack Henry's Fintech Integration Network.C Ask your digital banking and account opening providers which identity vendors they already connect to, and which data passes back to your core.
What your examiner will ask
Your CIP must include procedures to verify identity within a reasonable time after opening, and say when you use documents, non-documentary methods or both.7 Your Bank Secrecy Act (BSA) program must be written, approved by your board and reflected in board minutes.8 FinCEN's deepfake alert describes fraud typologies, gives red flags and reminds institutions of their BSA reporting duties.9 It notes criminals opened accounts with identities suspected to be made with generative AI.10 Have ready your updated CIP, a board-approved stance on digital IDs, your vendor due diligence and how your tool catches those red flags.
What it costs
Veriff lists three self-serve plans, priced per verification from $0.80.11 Sumsub lists a Compliance tier at $1.85 with a $299 minimum, including AML and proof-of-address checks.12 Socure does not publish pricing, and buyers report annual minimums starting around $50,000.13 Buyers also report Socure platform and support fees of $25,000 to $50,000, plus $48,000 to $96,000 for implementation.14
Persona's Essential plan starts at $250 a month on a 12-month contract.15 Vendr reports a $30,000 median annual contract for Persona.15 Vendr says Persona buyers at 1,000 to 5,000 verifications a month budget $25,000 to $75,000 a year.16 Vendr also reports Persona implementation fees of $5,000 to $25,000.17 FluxForce AI's fraud detection guide says to plan 90 to 120 days for a typical credit union integration.18 NCUA warns that some credit unions signed contracts with heavy termination penalties, though those terms are often negotiable.19 We'd compare per-verification rates and any annual minimums side by side.
Food for thought
FinCEN's FAQs let your CIP accept mDLs but do not require them.42
Dilly Labs research, written from our catalog and cited sources · updated . Credit unions pay nothing. Vendors pay a referral fee only when a contract is signed through us. It never changes rankings or this guide. How we work
Sources
- Fraud Surge: Synthetic Identities Drive Up Losses in Loan Portfolios - United Creditors Connectwww.unitedcreditorsconnect.com
A TransUnion fraud study revealed U.S. lenders lost a record **$3.2 billion to synthetic ID fraud in 2024**.
- Digital IDs And Customer Identification: What FinCEN’s New FAQs Mean For Onboarding - Financial Services - United Stateswww.mondaq.com
The FAQs do not make mobile driver's licenses mandatory.
- The new face of fraud: 5 emerging threats credit unions must address in 2026www.americascreditunions.org
These ghost profiles can bypass traditional identity verification and operate for months before defaulting, a process known as a "bust out."
- Digital IDs And Customer Identification: What FinCEN’s New FAQs Mean For Onboarding - Financial Services - United Stateswww.mondaq.com
The FAQs do not create a new rule.
- RISK MANAGEMENT TOPICSwww.nacha.org
***NOTE: As June 19 is a federal holiday, the practical effective date for these two rules will be the next banking day – Monday, June 22, 2026.
- ACH Fraud Rules Are Shifting: What Nacha 2026 Means for Banks and Credit Unions - ThreatMarkwww.threatmark.com
Nacha defines “false pretenses” as the inducement of payment by a person by misrepresenting (a) that person’s identity, (b) that person’s association ...
- Customer Identification Program (CIP) Requirements and Non-U.S. Personswww.americascreditunions.org
Furthermore, **section 1020.220(a)(2)(ii)** requires that the credit union’s CIP “contain procedures for verifying the identity of the customer, using...
- 12 CFR § 748.2 - Procedures for monitoring Bank Secrecy Act (BSA) compliance.www.law.cornell.edu
The compliance program must be written, approved by the credit union's board of directors, and reflected in the credit union's minutes.
- FinCEN Issues Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutionswww.fincen.gov
The alert explains typologies associated with these schemes, provides red flag indicators to assist with identifying and reporting related suspicious ...
- FinCEN: Deepfake Fraud Schemes Target Financial Institutionswww.americascreditunions.org
Criminals have successfully opened accounts using fraudulent identities suspected to have been produced with GenAI and used those accounts to receive ...
- Veriff pricing & KYC planswww.veriff.com
$1.39 per verification $99 minimum monthly commitment - All features included in the Essential plan.
- Sumsub Pricing & Planssumsub.com
$299 min.
- Socure Pricing Explained: Per-Verification Costs, Contract Minimums, and TCOfintechspecs.com
- Annual contract minimums reported by buyers start around $50,000 and scale with usage tiers.
- Socure Pricing Explained: Per-Verification Costs, Contract Minimums, and TCOfintechspecs.com
Add estimated platform and support fees of $25,000 to $50,000 annually, plus one-time implementation costs of $48,000 to $96,000 in year one, and the ...
- Best KYC and AML Software for Fintechs 2026: 8 Platforms Compared on Price and Coveragewww.complianceaiscout.com
The Essential plan starts at $250 a month on a 12-month contract, and Vendr reports a $30,000 median annual contract across 59 purchases.
- Persona Software Pricing & Plans 2026: See Your Costwww.vendr.com
- **Early-stage buyers (1,000–5,000 verifications/month):** Budget $25,000–$75,000 annually, with per-verification costs between **$1.50–$3.50** - **...
- Persona Software Pricing & Plans 2026: See Your Costwww.vendr.com
## Persona vs. Onfido ### Pricing comparison · Pricing component · Persona · Onfido · Document verification (per check) · $1.50–...
- Fraud Detection Credit Unions: 5-Step Guide - FluxForce AIwww.fluxforce.ai
Plan 90 to 120 days for a typical credit union integration.
- Evaluating Third Party Relationshipsncua.gov
For example, some credit unions have entered into third party agreements with significant buyout or termination penalties, believing the penalties or ...