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Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act) and its implementing regulations (31 CFR 103.121) require us to:

Verify the identity of any person applying for a mortgage loan, to the extent reasonable and practicable.

Maintain records of the information used to verify the person’s identity, including name, address, and other identifying information.

Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the financial institution by any government agency.

VERIFYING IDENTITY

In connection with each 1st mortgage or home equity loan application, we obtain enough information to form a reasonable belief that we know the true identity of each customer. To this end, we obtain the following information on our loan application documents from each customer before opening an account:

Name
Date of birth
Residential or business street address
For a U.S. person, a taxpayer identification number or, for a non-U.S. person, one or more of the following:
A taxpayer identification number
Passport number and country of issuance
Alien Identification card number or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

Instead of obtaining a taxpayer identification number from the customer prior to opening the account, we may open an account for the customer if he or she has applied for, but has not yet received, a taxpayer identification number. In this case, we must confirm the customer has applied for the number by obtaining a certification from the customer or a copy of the application for the number, and we must follow-up to obtain the number from the customer within 30 business days after the account is opened.

To obtain the required information, we may rely on documents such as an un-expired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport.

KEEPING RECORDS

We make and maintain a record of all information obtained under our identity verification procedures, including:

The identifying information about a customer.
A description of any document we relied on, noting the type of document.
Any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date.
A description of the methods and the results of any other measures undertaken to verify the identity of the customer.
A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.

We retain the information for at least five years after the date the loan is paid off or transferred to a loan purchaser.

LIST CHECKING

Nationwide Mortgage Loans Corporation compares the name of each borrower to any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Treasury Department in consultation with the federal functional regulators. We do this within 30 business days after the loan application. We follow all federal directives issued in connection with the lists.

CUSTOMER NOTICE

We post a lobby notice, deliver a written notice and include a notice on our Web site, announcing our practice of requesting information to verify the identities of our customers for purposes of the customer identification procedures required by the USA PATRIOT Act.

USA PATRIOT Notice

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT

To help the government fight the funding of 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. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

USA PATRIOT Act Customer Identification Procedures (CIP) Checklist

Verifying Identity

We verify the identity of any mortgage loan applicant by obtaining the following information:

Name
Date of birth
Residential or business street address
For a U.S. person, a taxpayer identification number. For a non-U.S. person, one or more of the following:
A taxpayer identification number
Passport number and country of issuance
Alien identification card number or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

Instead of obtaining a taxpayer identification number from a customer prior to opening the account, we may open an account for a customer who has applied for, but has not yet received, a taxpayer identification number. In this case, we confirm the application for the number was filed before the customer applied for the loan, and we obtain the taxpayer identification number within a reasonable period of time after the account is opened. Documents used to verify identity may include any un-expired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport.

LIST CHECKING

We determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the financial institution or any government agency.

We have designated a person or department responsible for determining whether each new customer appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Treasury Department in consultation with the federal functional regulators.

Our designated person makes a determination within a reasonable period of time after a loan closes, or earlier, if required by another federal law or regulation or federal directive issued in connection with the applicable list.

We follow all federal directives issued in connection with the lists.

Customer Notice. We provide customers with adequate notice that we request information to verify identities as required by the USA PATRIOT ACT.