Customer Identification Policy

Marshall County Federal Credit Union, in compliance with the requirements of the USA PATRIOT Act is adopting this policy to establish the identity of individuals and entities opening accounts at the credit union.

Marshall County Federal Credit Union’s identification program will consist of this policy approved by the board of directors and the following procedures that include:

Verifying the identity of any member or entity seeking to open an account.

Maintaining records of the information used to verify identity, using either unexpired government-issued documents or non-documentary verification methods.

Determining whether the member appears on any government list provided to the credit union by federal agencies, when these lists are issued.

In developing and maintaining appropriate procedures, management will take into consideration the types of accounts offered, the method of establishing accounts and this credit union’s field of membership to determine what level of risk the credit union has in opening accounts.

For purposes of this customer identification policy, accounts include all formal account relationships established including all share type accounts and loan type accounts. New members and customers establishing any type of account on or after October1, 2003 will be subject to the CIP procedures. The term customer includes nonmember joint owners, nonmember coborrowers or any other individual or entity establishing a formal account relationship with Marshall County Federal Credit Union who will not be a member.

Marshall County Federal Credit Union will require that every new member or customer provide a name, date of birth, address, and identification number prior to opening an account. This information will be maintained on file for five years after the account is closed. Marshall County Federal Credit Union will take reasonable steps to verify this information through documentary or nondocumentary verification methods as required by the Treasury Departments CIP regulations. These verification methods are specified in the credit union’s CIP procedures and the description of documents reviewed and the verification method used will be maintained for 5 years after the description is recorded.

This policy also requires additional verification for individuals whose true identity cannot be verified using the standard verification methods.

Marshall County Federal Credit Union will not maintain a new account if it cannot verify a member’s identity.

The Bank Secrecy Act officer or manager is responsible for maintaining ongoing compliance with the USA Patriot Act requirements and regulations.

Staff will be trained on these requirements.

An annual audit of CIP compliance will be conducted by the credit union’s supervisory committee or the board of directors.

Before opening an account, potential members and new customers will be advised of the credit union’s CIP program through appropriate notice.

Marshall County Federal Credit Union believes that is has a reasonable basis to assume that members and customers of record as of October 1, 2003 are known to the credit union. If events occur that raise questions as to whether the credit union know the true identity of a person, the credit union will seek to verify the person’s identity as called for in the CIP procedures.