0. WageWorks & BNY Mellon Customer Identification Program (CIP)
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WageWorks & BNY Mellon Customer Identification Program (CIP)

1. 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

2. 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

3. 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

4. CIP Letters – Initial & Reminder

5. CIP Letters – Initial & Reminder

6. CIP Letters – Final Notice

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