Customer Information Program (CIP) is a combination of requirements set forth in Section 326 of the USA Patriot Act. The Act states that all financial institutions must verify the identity of individuals wishing to conduct financial transactions with them. A Health Savings Account (HSA) is a bank account regulated by federal banking laws which is why Ameriflex is required to follow the CIP verification process. The Customer Identification Program is intended to enable the bank to form a reasonable belief that it knows the true identity of each customer.
The CIP process is required for all participants who enroll in an HSA. Ameriflex will run the test to verify the identity of the enrollee. The verification process reviews the participant’s information below against two federal databases:
- Social Security Number
- home mailing address
- date of birth
- full legal name
Usually this happens behind the scenes without issue, but occasionally outdated or missing information will cause the bank to reach out for more information. If there are any irregularities, it could cause a CIP failure on the account. For example, if an employee recently moved, this could cause a CIP failure.
If an account fails the CIP process due to an address, nickname, or an incorrect date of birth, they will request additional information to verify the information that was provided. The notification will be sent via email, so please advise that participants pay attention to their emails. Some items that can be requested to be returned to Ameriflex are: copy of driver's license, copy of a birth certificate, and/or a copy of a utility bill, etc.
Some examples of why an employee may not initially pass the CIP process are as follows:
- SSN does not coincide with name and address
- SSN was issued prior to date of birth
- SSN registered as deceased
- Day, year or month of birth does not coincide with SSN
This is not a comprehensive list, but is provided as an example of possible scenarios.
Once the participant passes the CIP process, an HSA account number will typically be available to the employer within the next business day. Accounts cannot be funded until an account number has generated. Please note that these account numbers will need to be requested directly from your Client Relationship Manager if you are funding the accounts via direct deposit.
