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KYC/KYB Verification Requirements

In order to comply with Bank Secrecy Act (“BSA”) laws and implementing regulations, the following data must be collected and verified for every customer (individual, sole proprietor, beneficial owner, and business). If any of the identity elements are not verified through Alloy screening and third party data services, a manual review will be conducted by a member of Unit’s Fraud Operations and/or BSA Team.

Customer or Customer- related Type

Identity Element

Individuals Sole Proprietors Beneficial Owners

Name DOB

ID Number (SSN/ITIN/Passport) Physical Address (no PO Boxes)

Business

Name Address State of Registration EIN

Approved Documents to Verify an Individual’s Identity

The following document types may be used to verify an individual’s identity in compliance with the bank’s customer identification program (“CIP”). These documents may be used for individuals, sole proprietors, and beneficial owners (individuals or businesses that own 25% or more of the business). Instructions for calculating beneficial ownership may be found in the Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions . Acceptance of these documents is at the discretion of the reviewer. Additional documentation may be requested if the customer’s identity cannot be verified and/or if the veracity of the document provided is questionable.

Document Type

Verification Purpose

Document Notes

Document Formats

● Scanned image ● Photo of a physical document ● Screenshot ● Digital copy (PDF)

● ID Number

● Must be current within the last 2 filing years. ● Must include the full 9-digit SSN.

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