THE TIMES-PICAYUNE EMPLOYEES

FEDERAL CREDIT UNION’S

USA PATRIOT ACT-MEMBER IDENTIFICATION

Introduction:

The USA PATRIOT ACT requires financial institutions, including credit unions, to establish minimum procedures for identifying and verifying the identity of members seeking to open new financial accounts or to add new signatories to financial accounts.

Purpose:

The purpose of the Customer Identification Program (CIP) is to protect the U. S. financial system from money laundering and terrorist financing.  Also, the program would help protect members against fraud, including identity theft.  The program will be used in conjunction with The Times-Picayune Employees Federal Credit Union’s Bank Secrecy Act Procedures.

General Objectives:

To prevent and detect money laundering and the financing of terrorism.

Specific Objectives:

Section 326 of the USA PATRIOT ACT requires The Times-Picayune Employees Federal Credit Union to establish procedures to:

    .  Verify the identity of any person or entity seeking to open an account at TPEFCU

    .  Maintain records of the information used to verify the member identity; and

    .  Determine whether the person appears on any list of known or suspected terrorist

       or terrorist organization provided by any agency of the federal government.  In

       addition to the requirements of Section 326 of the USA PATRIOT ACT, the CIP

       program is required to include:

    .  Internal policies, procedures and controls to ensure ongoing compliance

    .  Designation of Connie Nanney, Manager as compliance officer

    .  An ongoing training program

    .  An independent auditor to test the program

Verification of Identity:

Information Required:

Each individual who establishes a new account with The Times-Picayune Employees Federal Credit Union must provide the following information prior to opening the account without exception:

    .  Name

    .  Date of Birth

    .  Residence if different from mailing address

    .  For U. S. persons, a taxpayer identification number such as social security number,

       or employer identification number for business accounts

If the account is being established for a business, The Times-Picayune EFCU recognizes an employer identification number may not be available at the time the account is opened.  In this instance, the new member will have 30 days to provide the appropriate information.

Any member who adds a signer to their account who is not a current member of TPEFCU

will be subject to the identity verification requirements, without exception.

For existing members, identity does not need to be verified when establishing or changing accounts if:

    .  The members’ identity was previously verified in accordance with the procedures

       outlined in this policy, or

    .  The employee has a reasonable belief that they know the true identity of the member

       (Such as formal procedures followed by The Times-Picayune Publishing Company upon hiring and issuing an employee badge)

Verification Requirements

Section 326 of the Act states the new/existing member is required to comply with the act.  Because of the documents required to show identification, notice must be provided stating the new document requirements.  Notices will be posted in TPEFCU office and

made available to hand to members inquiring about new accounts.  Notice will also be

placed annually in the December end of year statements to members.

In order to verify the identity of the new or existing member, at least one document must be a non-expired government issued photo identification card (Driver’s License or Military ID).  Any other documentation gathered from the member to verify the required information (The Times-Picayune Publishing Company or it’s entities ID Badge will be acceptable) is flexible and can include social security cards, certified birth certificates, etc.

The Times-Picayune EFCU acknowledges that some new members will not have a non-expired government issued photo ID card.  In those instances:

    .  If the account is being established for a minor, the guardian parent must provide the

       forms of identification provided and a social security card for the minor child.

Recordkeeping:

The employee of TPEFCU who opens the new account is required to photocopy each document provided.  Each employee will be responsible for insuring the photocopy is clear and legible.

The photocopy of the identification will be placed in each member’s file.  The members’

file will be retained for at least five years after the account is closed.

Comparison with Government Lists

The TPEFCU will regularly screen its member database for suspected or known terrorists.  This will be done based on lists provided by federal government agencies and include, but is not limited to: OFAC Blocked Countries, OFAC’s Specially Designated Nationals & Blocked Persons, Officials of OFAC Blocked Countries, all FBU lists, lists produced by the Dept. of Treasury, Federal Reserve, OCC, FDIC, OTS and State Department, and any

and all lists issued by the Federal Government in accordance with the USA Patriot Act.

The screening will be done when lists are received.  Screening may occur more frequently at the discretion of the TPEFCU.  The manager will be responsible for determining if there are any matches with the lists and will take appropriate action, including freezing accounts and reporting said individual (or entity) within 10 days, or filing a SAR for any match that cannot be immediately confirmed as a false match.

Training:

All employees will receive training during new employee orientation and annually.

Training will be coordinated and provided by manager.

Exemptions:

There are certain categories of persons opening certain deposit accounts who are exempt under the Bank Secrecy Act (12C.F.R. Sec. 103.34(a)) from providing a taxpayer identification number.  This policy may be amended to include those individuals if they are deemed to also be exempt under the regulation for the USA Patriot Act, as advised by the appropriate government agency, such as the NCUA or Dept. of Treasury.

Adopted by Board: _______June 27, 2001____