Customer Identification and Verification

In an effort to assist the government in the fight against funding terrorism and money-laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

In addition to the information we must collect under the Funds’ Anti-Money Laundering Program we will, at a minimum: verify, to the extent reasonable and practicable, the identity of any customer seeking to open an account; maintain records of information used to verify a customer's identity; and check that a customer does not appear on government terrorist lists, such as the list on Treasury's Office of Foreign Assets Control (OFAC) Web Site. The types of information that we will collect before opening an account are listed below.

Required Identifying Information

We will collect the following information for all accounts, if applicable, for any person, entity or organization prior to opening a new account (or is being granted trading authority over a new or existing account) and whose name is on the account or has authority over the account: the name and mailing and residential (or principal place of business) street address of the customer; the customer’s date of birth; and, for U.S. persons, the customer’s Social Security number or taxpayer identification number. For non-U.S. persons, the following information will be used to identify customers: a taxpayer identification number, passport and country of issuance, an alien identification card number or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph. Both entities and natural persons who have applied for, but have not received a taxpayer identification can open an account with the Fund(s) by providing an alternate form of identifying information as set forth above.

Procedures Upon Failure to Verify/Customers Who Refuse to Provide Information

If a potential or existing customer either refuses to provide the information described above, or appears to have intentionally provided misleading information, or the Fund cannot form a reasonable belief that it knows the true identity of the customer based on the information provided, the Fund(s) will not open a new account and, after considering the risks involved, may consider closing any existing account. In either case, the Fund(s) will report a customer’s refusal to provide such information or failure to verify the identity of a customer to the AML Compliance Officer who must then determine whether to file a Suspicious Activity Report (SAR) in accordance with applicable law.

Verifying Information

To the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by verifying and documenting the accuracy of the information we receive about our customers. In verifying customer identity, we will analyze any logical inconsistencies in the information we obtain.

Customer identity will be verified through documentary evidence, non-documentary evidence, or both. We will use documents to verify customer identity when appropriate documents are available and suitable to form a reasonable belief that we know the true identity of the customer. We may also use such non-documentary means, after using documentary evidence, if we are still uncertain about whether we know the true identity of the customer. Appropriate documentary information for verifying the identity of natural persons include the following:

  • An unexpired driver’s license, passport, or other government identification showing nationality, residence, and photograph or, for non-U.S. persons, an unexpired alien registration card or other government issued identification showing nationality, residence and photograph.

The following documentary information will be used to verify the identity of businesses:

  • A certificate of incorporation, a government-issued business license, any partnership agreements, any corporate resolutions, or similar documents.

Verification of customer identity through the use of non-documentary evidence is mandatory in the following situations: (1) when the customer is unable to present an unexpired identification card with a photograph; (2) when the documents the customer presents for identification verification are unfamiliar to the Fund(s); (3) when the customer and Fund(s) do not have face-to-face contact; and (4) when there are other circumstances that increase the risk that the Fund(s) will be unable to verify the true identity of the customer through documentary means. Under these circumstances, we will use the following non-documentary methods of verifying identity:

  • Contact the customer after the account has been opened (although we will not rely solely on customer contact as a means for verification);
  • Obtain financial statements from the customer;
  • Compare information obtained from the customer against public databases or other in-house or custom databases;
  • Compare information obtained from customer with information available from a consumer reporting agency (such as a credit report);
  • Check references with other financial institutions; and
  • Any other non-documentary means deemed appropriate.

We will verify the information at the time new accounts are opened, if possible, but in most situations no later than five business days after opening. We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any substantive discrepancy in the identifying information. We will maintain those records for five years after the account has been closed or the customer's trading authority over the account has ended. Verification records will be retained for five years after the record is made.

Using Government Provided Lists of Terrorists and Other Criminals.

Before opening an account, and on an ongoing basis, we will check to ensure that a customer does not appear on a list provided to us by the government, such as the Treasury’s OFAC List. The OFAC Web Site can be viewed at www.treas.gov/ofac. Because the OFAC Web Site is updated frequently, we will consult the list on a regular basis. In the event that we determine a customer, or someone with or for whom the customer is transacting, is on the OFAC List or is from or engaging in transactions with a person or entity located in an embargoed country or region, we will reject the transaction and/or block the customer's assets and file a blocked assets and/or rejected transaction form with OFAC. We will also call the OFAC Hotline at 1-800-540-6322.

Reliance on Other Financial Institutions

Due to the limited contact with potential and existing customers, the Fund(s) will rely on a network of brokers/dealers with whom the Fund(s) have selling agreements with to perform the initial customer identification and verification process. Outside broker/dealers must complete the required field on the account application regarding customer identification and retain such information in their records as required by law. The Fund(s) will then create and maintain a record of the type of document, any identification number contained in the document, place of issuance, and the issuance and expiration date, if any, and include a description of the methods and results of any measures undertaken to verify the identity of the customer from the information provided on the account application.

Notice to Customers

In accordance with Federal law and prior to opening an account, the Fund(s) will provide adequate notice to customers that it is requesting information from them to verify their identities. The Fund(s) will use the following method to provide notice to customers: for walk-in, and mail-in account applications, our customers will receive oral or written notice of the method(s) used for verification regarding their identity. The notice will also be included on the account application and posted on the Funds’ website.