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New Pilgrim Federal Credit Union
USA Patriot Act - Customer Identification Program

Introduction:

The USA PATRIOT ACT requires financial institutions, including credit unions, to establish minimum procedures for identifying and verifying the identity of members seeking to open new financial accounts or to add new signatories to financial accounts.

Purpose:

The purpose of the Customer Identification Program (CIP) is to protect the U. S. financial system from money laundering and terrorist financing. Also, the program would help protect members against fraud, including identity theft. The program will be used in conjunction with New Pilgrim Federal Credit Union’s Bank Secrecy Act Program.

General Objectives:

To prevent and detect money laundering and the financing of terrorism.

Specific Objectives:

Section 326 of the USA PATRIOT ACT requires New Pilgrim Federal Credit Union to establish procedures to:

  • Verify the identity of any person or entity seeking to open an account at New Pilgrim Federal Credit Union.
  • Maintain records of the information used to verify the member identity; and
  • Determine whether the person appears on any list of known or suspected terrorist or terrorist organization provided by an agency of the federal government.

In addition to the requirements of Section 326 of the USA PATRIOT ACT, New Pilgrim Federal Credit Union will establish procedures to:

  • Include internal policies, procedures and controls to ensure ongoing compliance.
  • Designate a compliance officer
  • Provide an ongoing training program, and
  • Audit the program.

Verification of Identity:

Each individual who establishes a new account with New Pilgrim Federal Credit Union must provide the following information:

· Name

· Date of Birth

· Residence if different from mailing address

  • Social Security Number, or If the account is being established for a business, an employer identification number. (If the employer identification number is not available at the time the account is opened, the new member will have 30 days to provide the appropriate information).

Any member who adds a signer to their account, who is not a current member of New Pilgrim Federal Credit Union, will be subject to the identity verification requirements, without exception.

For existing members, identity does not need to be verified when establishing or changing account if:

  • The members’ identity was previously verified in accordance with the procedures
    outlined in this policy, or
  • The employee has a reasonable belief that they know the true identity of the member (Such as a member of New Pilgrim Baptist Church, or New Pilgrim Day Care Employee, or New Pilgrim Towers Employee or Resident).

Verification Requirements

Section 326 of the Act states the new/existing member is required to comply with the act. Because of the documents required to show identification, notice must be provided stating the new document requirements. Notices will be posted on the website at www.npfcu.com as well as in the New Pilgrim Federal Credit Union and made available to hand to members inquiring about new accounts.

In order to verify the identity of the new or existing member, at least one document must be a non-expired government issued photo identification card (Driver’s License or Military ID).

New Pilgrim Federal Credit Union acknowledges that some new members will not have a non-expired government issued photo ID card. In those instances, if the account is being established for a minor, the guardian parent must provide the forms of identification provided and a social security number for the minor child.

Recordkeeping:

The employee of New Pilgrim Federal Credit Union who opens the new account is required to photocopy the government issued ID and write the employee’s initials on the membership card. Each employee will be responsible for insuring the photocopy is clear and legible as well as checking FEDCOMP software and printing out results to keep on file. The photocopy of the identification will be attached to the members’ record and will be retained for at least five years after the account is closed.

Comparison with Government Lists:

New Pilgrim Federal Credit Union will regularly screen its member database for suspected or known terrorists. This will be done based on lists provided by federal government agencies and include but is not limited to: OFAC Blocked Countries, OFAC’s Specially Designated Nationals & Blocked Persons, Officials of OFAC Blocked Countries, all FBI lists, lists produced by the Dept. of Treasury, Federal Reserve, OFF, FDIC, OTS and State Department, and any and all lists issued by the Federal Government in accordance with the USA Patriot Act.

The screening will be done when lists are received. Screening may occur more frequently at the discretion of New Pilgrim Federal Credit Union. The manager will be responsible for determining if there are any matches with the lists and will take appropriate action, including freezing accounts and reporting said individual (or entity) within 10 days, or filing a SAR for any match that cannot be immediately confirmed as a false match.

Training:

All employees will receive training during new employee orientation and annually.
Training will be coordinated and provided by manager.

Exemptions:

There are certain categories of person opening certain deposit accounts who are exempt under the Bank Secrecy Act (12C.F.R. Sec. 103.34(a)) from providing a taxpayer identification number. This policy may be amended to include those individuals if they are deemed to also be exempt under the regulation for the USA Patriot Act, as advised by the appropriate government agency, such as the NCUA or Dept. of Treasur



 

 

 Links to other websites from our website are provided solely as a member convenience.  We claim no responsibility for, or control over any non NPFCU site, content, or policies.  No endorsement or representation for any non NPFCU site, respective product, service or any additional information is made by NPFCU.

 

                                            

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