WEE Federal Credit Union

Policy: USA Patriot Act - Customer Identification Program Policy

July 14, 2004

A. PURPOSE OF THIS POLICY
The Board of Directors of the WEE Federal Credit Union adopted this Customer Identification Program (CIP) policy, as required by Section 326 of the USA Patriot Act. This CIP policy is effective immediately and is incorporated into our overall Bank Secrecy Act policy. This CIP policy will help our credit union detect and prevent money laundering and terrorist
financing schemes.

WEE Federal Credit Union understands that CIP requires the credit union to follow these basic steps when a member and or an account owner (hereafter known as “member”) opens a new account or when a new member is added to an existing account:

Provide a CIP disclosure
Obtain basic information about the member
Verify the identity of the member
Check if a member appears on a government terrorist list
Retain records for 5 years after the account has been closed.

B. POLICY GOALS

Verify the identity of any member opening a new account at WEE Federal Credit Union.
Maintain records of information used to verify the identity of members opening new accounts for a period of 5 years after the account has been closed.
Cross-check names of members opening new accounts against lists of known or suspected terrorists/terrorist organizations provided by agencies of the US government.
Provide for internal procedures/controls to ensure ongoing CIP compliance by the WEE Federal Credit Union staff.

C. GENERAL PROVISIONS

1. Applicability

This CIP policy applies to:

Any new member opening an account at WEE Federal Credit Union.
Any new member added to an existing member’s account.
EXCEPTION: This CIP policy does not apply to existing members of WEE Federal Credit Union opening new accounts as long as:

Existing member identity was previously verified.
Employee of WEE Federal Credit Union has a reasonable belief he or she knows the identity of the member.

2. Member Notice

To our account holders and potential account holders:

In accordance with Section 326 of the USA Patriot Act of 2001, which requires the WEE Federal Credit Union to help the government fight the funding of terrorism and money laundering activities, WEE Federal Credit Union is required to obtain basic identifying information from you and verify that information when you open a new account.

This means the WEE Federal Credit Union staff will ask you for some basic information such as your name, address, date of birth, and other information designed to help us identify you. WEE Federal Credit Union staff will also ask to see documents identifying you such as a social security card, driver’s license, passport, and/or some other government-issued document.

In some cases, identification will be requested for those individuals conducting business with WEE Federal Credit Union prior to the effective date of the member identification requirements. This is because original documentation was not obtained with the opening of the account or WEE Federal Credit Union is unable to form a reasonable belief that it knows the true identity of the existing account holder.

In all cases, protection of our member’s identity and confidentiality is the Credit Union’s pledge to you. WEE Federal Credit Union appreciates your patience and understanding as we all do our part in complying with the new account identification procedures required by the federal USA Patriot Act of 2001.

Respectfully,

The Board of Directors, Staff and Members of the WEE Federal Credit Union

Notice shall be given to new account owners in any of the following ways:

Oral notice given to new account owners, in person or on the phone
Lobby notice
Brochure/paper notice included in new member packets
Signs at Member Service Representative stations
Notice posted on new account pages of WEE Federal Credit Union website

D. PROCEDURES

1. Opening a New Account—Collecting Basic Information

Any member who wishes to open a new account with WEE Federal Credit Union must provide the following basic information BEFORE opening an account:

1) Name as it appears on the social security card

2) Date of Birth

Address, which shall be:
For an individual, a residential or business street address;
For an individual who does not have a residential or business street address, an Army Post Office (AP0) or Fleet Post Office (FPO) box number, or residential or business street address of next of kin or of another contact individual; or
For a person other than an individual (such as a corporation, partnership or trust), a principal place of business, local office or other physical location; and

4) Identification Number

a) US Persons:

Social Security Number
Employer Identification Number (for business accounts)

b) Non-US Persons (1 or more of these):

9-Digit Individual Tax Identification Number
Passport Number & Country of Issuance
Alien Identification Card Number (Green Card)
Document Number & Country Issuing any "other" document” showing evidencing nationality or residence and bearing a photograph or similar safeguard.

If the member is applying for a TIN/SSN or a card is not available, WEE Federal Credit Union will accept a letter from the social security administration documenting that the card has been applied for or reissued. We will require the member to produce the card within three months time. In the case of an infant or adopted minor, identification numbers will be required from the parent(s) on the account. Minors without an identification number will be monitored on a monthly basis with Member Service Representatives contacting the parents each month until the card is produced at the credit union.

2. Verifying Required Information—Methods Used

When a new member opens an account, WEE Federal Credit Union staff shall use both “document and “non-document” methods to verify the identity of all new account owners. If an account is requested through the mail or Internet, it will not be opened until document information and a signed account card are received.

Document Identification includes requiring any of the following (listed in order of preference:

Unexpired Government Issued Drivers License****(Some credit unions choose to retain a photocopy of the member’s driver’s license. This is NOT a requirement of the regulation, this is the choice of the credit union. The only requirement is that the driver’s license number and date of expiration be recorded. Credit unions should also be aware that in certain states, it is illegal to make a photocopy of a driver’s license. Each credit union must be aware of the laws in their state regarding this issue. Credit unions must also be aware that if they do retain a copy of the driver’s license, it cannot be kept with loan files. It is recommended credit unions discuss the legal issues of retaining a copy of the drivers license with their legal counsel.
Unexpired Government Issued Identification Card
Passport
Employer Identification Card
Student Identification Card
Other National Identification Document
For person other than an individual (such as a corporation, partnership or trust), documents showing the existence of the entity such as:

Certified articles of incorporation
Government-issued business license
Partnership agreement, or
Trust instrument.

Non-Document Identification includes any of the following:

Contact new member’s employer
Check references at other financial institutions
Contact new member’s family member
Compare member information against credit report, public database or other source
Obtaining a financial statement

Additional verification for certain customers: Based on the credit union’s risk assessment of a new account opened by a customer that is not an individual, the credit union will obtain information about individuals with authority or control over such account, including signatories, in order to verify the customer’s identity. This verification method applies only when the credit union cannot verify the customer’s true identity using the verification methods described above.

3. Special Circumstances—Lack of Verification

In situations where WEE Federal Credit Union cannot form a reasonable belief regarding the identity of a new account owner (either due to lack of document identification or non-document verification) the staff at WEE Federal Credit Union will:

****The credit union must choose either (a) or (b) below, not both.

If (b) is chosen, then (c) applies.

Not open the account.
Open the account, however, the member will only be allowed to perform the following transactions while the bank attempts to verify the member’s identity:

****The following transactions are just examples, each credit union must customize this to tailor their program.

Make deposits
Make withdrawals

If attempts to verify the member’s identity have failed, the account will be closed within 10 days of the date of opening. ***The credit union must specify a reasonable time frame here.
A Suspicious Activity Report will be filed in accordance with applicable law and regulation.

4. Comparison with Government Lists

WEE Federal Credit Union will crosscheck the name(s) of any new member against any list of known or suspected terrorists or terrorist organizations issued by any Federal government agency and designated as such by Treasury in consultation with the Federal functional regulators. This determination will be made at the time the account is opened. WEE Federal Credit Union will follow all Federal directives issued in connection with such lists. Any member whose name appears on any of the above-mentioned lists may not be permitted to open an account at WEE Federal Credit Union.

5. Record Retention—Five Years

CIP requires WEE Federal Credit Union to “make and maintain” a record of all identifying information received from new account owners for a period of five years AFTER an account is closed.

Record retention shall consist of a description of any document used to establish identity, to include:

Type of document (e.g., drivers license, passport)
Any identification number on the document
Place document was issued, expiration date of document

When using non-documentary methods to verify identity (e.g., credit report, calling employer), and requesting additional verification for certain customers, WEE Federal Credit Union shall:

Identify the non-document method used (e.g., called employer)
Document results of this verification method (e.g., employment at XYZ School District confirmed by payroll office)

When any substantive discrepancy is discovered when verifying the identifying information, a description of the resolution will also be maintained.

E. RESPONSIBILITY

The Manager will be responsible for implementing the CIP and will assume responsibility for ongoing compliance with the CIP.

F. TRAINING

All credit union personnel who might, in the daily course of business, open new accounts are to be given intensive training in the requirements of the CIP. Additionally, all employees will be given an overview of the CIP on an annual basis

G. ANNUAL REVIEW

This policy will be reviewed by the board of directors on an annual basis.

General Provisions

Each new applicant for membership to WEE Federal Credit Union shall provide to the credit union teller a minimum of two forms of identification one of which must be an identification issued by a governmental institution. Some examples are as follows:

Driver’s license
Social Security Card
Birth Certificate
Passport

Each account including all join owners of accounts must have a valid social security number, birth date and address as part of their identification.

The WEE Federal Credit Union will copy the sources of information and hold them on file for five years past the closure of the account by the member.

The new member shall not be permitted to open any accounts other than the basic savings account until verification of the new member can be obtained by the credit union by the processor performing WEE Federal Credit Union verification and information. Currently this process occurs each Tuesday with reporting to the Credit Union on Wednesday.

Once verification is obtained the new member will be accepted and may proceed to access the full services of the WEE Federal Credit Union.

Feel free to contact us if you have any questions about this policy.