Customer Identification Program

1. Overview

This Notice explains PayServices Bank's Customer Identification Program ("CIP"), established and maintained in accordance with section 326 of the USA PATRIOT Act, 31 U.S.C. § 5318(l), and its implementing regulations at 31 CFR § 1020.220 (for banks) and Idaho law. The CIP is a foundational element of PayServices Bank's anti-money-laundering and counter-terrorist-financing compliance program.

2. Required federal notice

This notice is the form prescribed by the regulators for use by U.S. banks under 31 CFR § 1020.220(a)(5). It is provided to you in connection with the opening of every new account at PayServices Bank.

3. Information we collect

For each customer who opens an account, we collect, at minimum:

• Name — full legal name;
• Date of birth — for individuals;
• Address — residential or business street address (or, where appropriate, a U.S. Army Post Office or Fleet Post Office address; an Indian reservation address; or, for non-U.S. persons, a residential or business street address in their country of residence);
• Identification number — for U.S. persons, a Taxpayer Identification Number ("TIN") (Social Security Number, Individual Taxpayer Identification Number, or Employer Identification Number); for non-U.S. persons, a passport number and country of issuance, or other government-issued identification number bearing a photograph or similar safeguard.

For accounts opened by legal entities, we collect additional information about the entity and its beneficial owners, as described in the Beneficial Ownership Disclosure.

4. How we verify your identity

We use a risk-based combination of documentary and non-documentary methods to verify your identity, as required by 31 CFR § 1020.220(a)(2)(ii):

• Documentary verification — review of unexpired government-issued identification bearing a photograph or similar safeguard, such as a driver's license, passport, or national identity card. For business accounts, we additionally review formation documents, certificates of good standing, or equivalent. We may use trusted third-party identity-verification providers to capture and authenticate identification documents (including by document-image authentication and biometric face-match).
• Non-documentary verification — comparison of the information you provide with information obtained from consumer reporting agencies, public databases, or other reputable sources; checks for the logical consistency of identifying information; and other procedures appropriate to the level of risk.
• Additional procedures for higher-risk circumstances, including politically exposed persons, customers in higher-risk jurisdictions, and accounts where the customer cannot be physically present.

5. Watchlist screening

For each customer, we screen the customer's identifying information against the lists of known or suspected terrorists, sanctioned persons, and other restricted parties maintained by the U.S. Treasury Office of Foreign Assets Control ("OFAC"), the United Nations, and other competent authorities. Where a screening match is identified, we follow the applicable regulatory procedure, which may include freezing of property, blocking of transactions, or reporting to FinCEN, OFAC, or another competent authority.

As described in the Terms of Service, inclusion on a sanctions list does not in itself prohibit use of ITAM. The compliance status of each transaction is evaluated on the specific facts presented (the who/what/where/how/when test), and access to specific features may be limited where required by an applicable sanctions regime.

6. Recordkeeping

We maintain records of the identifying information you provide and the methods we used to verify it, for the period required by law (generally five years after an account is closed). These records are protected by appropriate security measures and are accessible only to authorized PayServices Bank personnel and competent authorities.

7. If we cannot verify your identity

If we cannot reasonably verify your identity through the methods described above, we will not open the account, will close any account that has been opened, or will limit the account's functionality until verification can be completed, in accordance with our written CIP. We will provide you with a clear explanation in such cases, and where possible, an opportunity to provide additional information or documentation.

8. Ongoing customer due diligence

In addition to identifying customers at account opening, we conduct ongoing customer due diligence over the life of the relationship, in accordance with the FinCEN Customer Due Diligence Rule (31 CFR § 1010.230). This includes monitoring transactions for suspicious activity, updating identifying information as appropriate, and re-verifying customers in higher-risk circumstances.

Reporting and information sharing. Where ongoing monitoring identifies activity that we know, suspect, or have reason to suspect involves money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful activity, we file a Suspicious Activity Report ("SAR") with the U.S. Treasury Financial Crimes Enforcement Network ("FinCEN") in accordance with 12 CFR Part 353 and 31 CFR § 1020.320. Federal law prohibits us from notifying you, or any person involved, of the existence or contents of a SAR. We also participate in voluntary information sharing with other financial institutions under section 314(b) of the USA PATRIOT Act (31 CFR § 1010.540) and respond to information requests from FinCEN under section 314(a). The legal effect on the relationship between you and PayServices Bank of these reporting and information-sharing obligations is described in the Terms of Service, Section 12 and Section 16.

9. Additional information for international correspondent banking

Where PayServices Bank establishes or maintains a correspondent account for a foreign financial institution, additional procedures apply under sections 312 and 313 of the USA PATRIOT Act (31 U.S.C. §§ 5318(i), 5318(j)) and 31 CFR § 1010.610. Counterparties on the PayServices Network are required to provide enhanced due-diligence information, including beneficial-ownership information and certifications regarding shell-bank prohibitions.

10. Contact us

PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States

info@payservices.com