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Customer Identification Program

CIP

OBJECTIVES

CIP Objectives

What's the primary focus of CIP?

Where did the emphasis come from?

Why is it important?

How did this impact our institution?

When did it take effect?

Who does this affect?

ORIGIN

When did it take effect?

On OCTOBER 26, 2001, President Bush signed into law the USA PATRIOT act.

Uniting and

Strengthening

America by

Providing

Appropriate

Tools

Required to

Intercept and

Obstruct

Terrorism

ORIGIN Continued...

-Section 326 of the Act requires the establishment of minimum standards that financial institutions must meet to identify a customer before opening an account.

  • An account is defined as a formal relationship with DCFCU that provides ongoing products and services such as deposit accounts and loans. Also refers to the relationship established to provide a safe deposit box, cash management, custodian or trust services.
  • A customer (DCFCU MEMBER) includes any person who opens an account or are a joint account owner.

FOCUS

Focus of Customer Identification Program (CIP)

Anti-Money

Laundering

USA PATRIOT Act

Bank Secrecy Act

Other Government-Directed Lists

(BSA)

(AML)

Office of Foreign Assets

(OFAC)

ACCOUNT OPENING

At account opening...

The following information must be obtained through identification materials prior to opening an account:

  • Legal Name
  • Date of Birth
  • Social Security Number
  • Address (if 'stated address' does not match state ID address, proof of address is required)
  • No P.O. box
  • Exception: if no residential address --> Armed Forces Post Office or Fleet Post Office

Our Institution's Policies, Procedures, and Controls

-It is the policy of the Credit Union to request:

  • Two pieces of documentation: a primary form of identification and a second form of identifcation. Both must be VALID.

Account Opening Procedures (pg.2 of 2-2002)

Acceptable Primary Identification:

Acceptable Secondary Identification:

Item

  • FL Driver's License
  • FL ID Card
  • US Passport
  • Alien Identification Card for Permanent Residents

Out-of-State DL only if family member of known existing member with Operations approval.

USE your branch's current ID book and black light to chek the validity of suspicious IDs.

  • Major Credit/Debit card
  • Student ID
  • Voter's Registration Card
  • Concealed Weapons
  • Foreign Passport

Other secondary IDs may be accepted based on member's age 65+

-Member can use two different primary IDs in lieu of a Primary/Secondary except using both FLDL & FLID.

NON-DOCUMENTARY VERIFICATION

INTERVIEWING

METHODS

Methods which may be utilized:

  • Interviewing the potential member(s)
  • Contacting the member after the account is opened (follow-up)
  • Checking references (phone numbers)
  • Checking prior financial institution account relationship; comparing information with Chexsystems
  • Comparing information provided by potential member with credit report (potential cross-selling)

INTERVIEWING TIPS

Interviewing Tips:

During the account opening process, it's OKAY and it's IMPORTANT to ask questions.

  • Why do you want to be a member with DCFCU?
  • How did you hear about DCFCU?
  • What brought you to this particular branch?
  • Have you lived in Miami your whole life?
  • How long have you lived at your current residence?
  • How long have you been with your employer?

-Observe potential member's body language and how they answer questions

-Compare answers to Efunds, Chexsystems, and Credit Report(s).

WARNINGS

During the new account opening process be aware of certain warning signals...

  • Potential member appears to be in a rush or fidgety
  • Potential member gives vague answers
  • Potential member appears to be reluctant to provide answers or proper identification
  • Potential member avoids providing necessary information
  • Potential member terminates account process when informed documentation will be verified
  • Structuring or future transactions seem to be a concern for potential member
  • Potential member requests to be on CTR Exempt List

Other warning signals...

-Large currency withdrawals from an account that has no prior history of such transactions.

-Significant international wire transfer activity (both receiving and sending)

QUESTIONS

Customer Identification Program

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