Wage Works BNY Mellon Customer Identification Program CIP

Customer Identification Program (CIP) CIP Requirements According to the US PATRIOT Act of 2003, financial institutions are now required to obtain, verify, and record specific information. The following information is collected at time of enrollment for CIP (Customer Identification Program): § First Name, Last Name § Residential Address § DOB § SSN § Home Phone CIP Review typically begins within a week of the account being opened at BNY Mellon 1

Customer Identification Program (CIP) Employer Advantage BNY Mellon developed a patent-pending process for verifying the identity of account owners to comply with regulatory obligations related to Section 326 of the USA PATRIOT Act. This process includes: • Prerequisites to Opening an Account • Non Documentary Verification Method • Government List Matching • ‘Failure to Identify’ Situations • Document Verification Method 2

CIP Failure Timeline Days 1 -5 Days 16 -55 Days 70 -89 Day 90 • Correspondence letter sent by custodian to the account owner • Reminder notice sent to the account owner • Liquidation notice sent to the account owner • Account liquidated and closed • Proceeds are sent to the account owner BNY notifies Wage. Works of unverified accounts Wage. Works interacts with Employer to encourage verification 3

CIP Letters – Initial & Reminder 4

CIP Letters – Initial & Reminder 5

CIP Letters – Final Notice 6