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← All Disclosures·Customer Identification Program

Customer Identification Program Notice

Effective · July 11, 2026

Important Information You Need to Know.

To help the government fight the funding of terrorism and money laundering activities, federal law — Section 326 of the USA PATRIOT Act and the customer identification program rule for broker-dealers (31 CFR 1023.220, administered by the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN)) — requires financial institutions to obtain, verify and record information that identifies each person who opens an account.

This notice answers some questions about our Customer Identification Program.

01

What types of information will I need to provide?

When you open an account, we are required to collect the following information:

  • Name
  • Date of birth
  • Address
  • Identification number
    • U.S. citizen: taxpayer identification number (Social Security number or employer ID 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.

We may verify the information you provide using documents, non-documentary methods (such as comparing the information against data from a consumer reporting agency or other third-party database), or both. We also check your name against government-maintained lists of known or suspected terrorists or terrorist organizations, including lists administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC).

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.

FINRA, U.S. Treasury Department and SEC rules also 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.

02

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

If you do not provide the information we request, or if we are unable to verify your identity, we may not be able to open or maintain your account. We may also be required to restrict or delay your transactions, or to close your account, while we attempt to verify your identity.