The PATRIOT Act Disclosure is provided pursuant to the provisions of 31 USCA § 5318 (West 2012) and 31 CFR § 1020.220(a)(5) (2012). Under the latter subsection of law, a notice is required to be provided to customers before they open an account, informing them that a bank is attempting to verify their identities. The notice must describe the identification requirements of 31 CFR § 1020.220 and a sample notice is promulgated, which may be used for compliance with this section when appropriately used.
Currently, we have been using a truncated version of the same notice on our PATRIOT Act Disclosure, which satisfactorily complies with the section’s notice requirement. Following our policy of using the exact language of a model or sample form as far as possible, we will be revising the language of this notice to match the sample notice, to wit:
“To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.”
In order to add the extra language of the sample notice, while keeping the document to one page, the font-size for the entire document will be reduced to 8-point type. In addition, citations to applicable laws will be included in the footer.
This change will only be to the generic version of Cx2531 and not to customized versions. Clients with a customized version, who would like the language of the complete sample notice to print in their version, will need to request this through their Account Manager or Client Support.
The update to the new version will take effect in ConformX on February 28, 2013. If you have any questions or concerns about this update, please contact Client Support at 1.800.497.3584.
February 20, 2013