Customer Identification Program Notice

Important Information You Need to Know About Opening a New Account with Our Firm and Its Affiliates

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.

This Notice answers some questions about your firm’s Customer Identification Program.

What types of information will I need to provide?

When you open an account, our firm and its affiliates are required to collect information from you such as the following:

  • Your name
  • Date of birth
  • Address
  • Identification number
    • U.S. Citizen:  taxpayer identification number (social security number or employer identification number)
    • Non-U.S. Citizen:  taxpayer identification number, passport number and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.  You may also need to show your driver’s license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement.  U.S. Department of the Treasury, Securities and Exchange Commission, NASD, and New York Stock Exchange rules already require you to provide most of this information.  These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.

What happens if I don’t provide the information requested or my identity can’t be verified?

Our firm and its affiliates may not be able to open an account or carry out transactions for you.  If our firm and its affiliates have already opened an account for you, it may have to be closed.  We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.