"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.
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
I received a PFA Incomplete Notice. What should I do?
Based upon your feedback, and to further improve our CIP process, we added an Incomplete Addendum for select clients and made the original CIP Disclosure Addendum more dynamic by displaying data provided to us at the time of the quote. This should make it easier for you to know what information we have and what is still needed from you and your insured.
What sort of information is required from insureds?
For compliance with the stipulations of the USA Patriot Act, we're required to obtain and verify the following:
- The insured’s legal name in full
- The insured’s physical-location address (not only a PO box number or registered agent address)
- For sole proprietors or individual consumers: Your federal employer identification number (FEIN) and/or Social Security number (SSN) with date of birth (DOB).
What if an insured's identity can't be verified?
We may not be able to open an account for you or continue to fund your policy when it comes up for renewal. We thank you for your patience and hope that you'll support the overall efforts to deny terrorists and money launderers access to the US financial system.
Do insureds have to supply this information every year they finance with Prime Rate?
Not necessarily. As long as the information submitted with the initial application passes the government’s CIP requirements, the information provided with the initial finance request will remain valid as long as there are no substantive changes such as a change of address.
Does Prime Rate ever contact an insured directly, if the required information isn't provided by the insurance agent or broker?
If the required information isn't provided by the agent or broker, one of our CIP team associates may contact you or your insurance agent to obtain the required information. In some cases, insureds may receive a letter in the mail from us, requesting they provide the required information.
If an agent or borrower wants to provide the required information over the phone, is that acceptable?
Yes. We accept information over the phone.
I do business in Canada. Is CIP a requirement for CAFO Premium Installment Contracts (PICs) and cross-border transactions?
In Canada, Premium Finance Agreements (PFAs) for insureds conducting business in the United States will include the USA Patriot Act Customer Identification Program (CIP) Disclosure Notice for compliance with US federal law (the USA Patriot Act), which requires CAFO and/or its affiliate Prime Rate and AFCO to obtain, verify and record information about anybody, including insureds, who opens an account with AFCO/CAFO/Prime Rate or establishes a relationship with our company in the US.
What is the difference between “establishing a relationship” and “opening an account”?
An entity or an individual could seek to establish a relationship with us without getting to the point of actually opening an account with us.
How will you protect my information?
To protect client information from unauthorized access and use, we implement structured security measures that include technology systems and computer safeguards, secured files and buildings, and systematic processes and procedures. All measures comply with federal law.