WageWorks & BNY Mellon Customer Identification Program (CIP) ____ __ WageWorks & BNY Mellon Customer Identification Program (CIP)

Customer Identification Program (CIP) CIP Requirements According to the US PATRIOT Act of 2003, financial institutions are now required to obtain, verify, and record specific information. The following information is collected at time of enrollment for CIP (Customer Identification Program): First Name, Last Name Residential Address DOB SSN Home Phone  CIP Review typically begins within a week of the account being opened at BNY Mellon

Customer Identification Program (CIP) Employer Advantage BNY Mellon developed a patent-pending process for verifying the identity of account owners to comply with regulatory obligations related to Section 326 of the USA PATRIOT Act. This process includes: Prerequisites to Opening an Account Non Documentary Verification Method Government List Matching ‘Failure to Identify’ Situations Document Verification Method

CIP Failure Timeline Days 1-5 Correspondence letter sent by custodian to the account owner Days 16-55 Reminder notice sent to the account owner Days 70-89 Liquidation notice sent to the account owner Day 90 Account liquidated and closed Proceeds are sent to the account owner BNY notifies WageWorks of unverified accounts WageWorks interacts with Employer to encourage verification CIP review begins within a week of the account opening with BNY Mellon

CIP Letters – Initial & Reminder

CIP Letters – Initial & Reminder

CIP Letters – Final Notice

©2013 WageWorks Inc. All rights reserved.