Patriot Act Compliance Policy/Procedures
The Credit Union adopts this policy in recognition of the Credit Union's obligations under the Patriots Act and regulations and requirements of NCUA for compliance with the act.
The Credit Union shall obtain certain required information in connection with the opening of a new account. For each person the Credit Union will obtain the following information:
- Date of Birth
- An address - which must be residential or business street address.
- If an individual does not have a residential or business street address they should provide an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or another contact individual.
- For a person other than an individual (such as a trust), a principal place of business, local office, or other physical location.
- A Government issued identification number.
- For a U.S. person, a taxpayer identification number.
- For a non-U.S. person - one or more of the following:
A taxpayer ID number, a passport number or country of issuance, alien identification card number or number and country of issuance of any other government issued document evidencing nationality or residence and bearing a photograph or similar safeguard.
The Credit Union has adopted methods which will allow them to verify that the individual(s) opening an account are who they say they are. Identifying information will be verified within 5 business days depending on:
- What type of account has been opened
- Whether all parties are present at opening
- Type of Identification presented
The Credit Union shall use documentary and non-documentary methods to verify an individual's identity.
Primary Identification Used for Documentary Verification:
For a U.S. person
- Driver's License
- State ID
- Commercial Driver's License
- Military ID (three forms)
- Federal Government Employee ID Card
- Permanent Resident Card
For a non-U.S. person
- Alien Registration Card
- Nonresident Alien Border Crossing Card
- Nonimmigrant Visa and Border Crossing Card
- Employment Authorization Card
The Credit Union will also pull credit reports through Equifax once an account has been opened to verify member's identity. Non-documentary verification should be used in such instances when accounts are opened without a face-to-face transaction, when a government-issued form of identification is not present or when the Credit Union will not be able to verify the true identity of the member. Other verification methods may be used in these cases to include:
- Contacting the member at the address provided.
- Sending a Thank You card to the address provided.
- Comparing the indentifying information provided by the member against fraud and bad check databases to determine any incidents or fraudulent behavior.
When the Credit Union is unable to verify a person's identity the following procedures should be followed:
- If an account has not yet been opened, the Credit Union will refuse to open the account if the true identity of the person in question cannot be verified.
- If the account has already been opened the Credit Union will place a hold or freeze on the account until they can verify the true identity of the person in question. If the Credit Union is ultimately not able to verify the true identity of the person in question then the account will be closed and any funds will be returned to the individual.
- If a person attempts to open an account with false identification, the Credit Union will complete a Suspicious Activity Report (SAR).
The Credit Union will check any new or potential members against any government-issued list of known terrorist such as the OFAC list and the 314A requests from FINCEN. A determination of whether the applicant appears on any list will be made at the time of the account opening. If at any time in the process a name matches a list, all procedures will be stopped and the BSA officer will be notified and the Proper Regulatory Agency will be notified immediately.
Record Retention - The Credit Union will maintain all documents pertaining to a members account for a period of at least five years after the accounts have been closed.
This policy was approved by the Board of Directors in May 2013.