"Know Your Customer" requirements
In accordance with the USA Patriot Act, we've implemented a Customer Information Program (CIP) as required by federal law. CIP is aimed at obtaining, verifying and recording verifiable information on customers seeking to open an account for the purpose of obtaining a loan.
What is the CIP?
The CIP is a government program that requires us and other lenders to identify anybody seeking to open an account. By federal law, we must verify the identity of all customers and retain client information.
Model : "stack"
Position : "left"
The federal government requires lenders such as us to implement a CIP program for compliance with the USA Patriot Act, which was enacted as part of the effort to fight terrorism and money laundering. The Patriot Act was made law as an amendment to the Bank Secrecy Act following the tragic events of September 11, 2001.
The USA Patriot Act stipulates that banks and financial services companies like us are compelled to obtain what is known as Personally Identifiable Information about individuals and entities doing business with them. Section 326 of the USA Patriot Act requires financial institutions to implement procedures that enable them to form a reasonable belief that they know the true identity of the client.
More specifically, Section 326 requires “banks, savings associations, credit unions and certain non-federally regulated banks" to have a CIP. The program's aim is to identify anybody seeking to open an account, verify the identity of that individual or entity, and retain client information.
What's the CIP process and program enhancements?
We've made several system and program enhancements aimed at making it easy for everyone to be in compliance with this program, including:
- Providing a CIP Disclosure Addendum to all PFAs requesting the insured’s information
- Creating CIP data entry fields in our quoting applications
- Utilizing third-party data providers to provide missing CIP data, where possible
- A direct-mail campaign to insureds asking for their CIP information