[17405]
April 20, 2004
TO: MONEY LAUNDERING RULES WORKING GROUP No. 13-04
OPERATIONS COMMITTEE No. 8-04
TRANSFER AGENT ADVISORY COMMITTEE No. 37-04
RE: TAAC CUSTOMER IDENTIFICATION PROGRAM SURVEY RESULTS
The Transfer Agent Advisory Committee established a task force last year, chaired by
Charles Hawkins of PNC Financial Services Group, which developed the 2003 Customer
Identification Program (CIP) Survey. This survey was designed to gather information
regarding mutual fund transfer agents’ Customer Identification Program practices and
procedures to comply with the final rules under the anti-money laundering provisions of the
USA PATRIOT Act.
Sixty mutual fund families completed the survey. The survey results, including a listing
of the mutual fund survey participants, and the blank survey questionnaire are attached for
your review. The survey results include data collected from respondents on risk assessment,
notice, information receipt and identity verification, failure to verify customer identification,
government lists, administration, and recordkeeping processes and procedures.
The ICI solicited data from member complexes for informational purposes only. All
survey responses were aggregated and no individual complex data have been distributed or
discussed in the final document. The aggregate survey results will be reviewed and discussed
at future ICI Committee meetings. Each member should independently review and utilize such
aggregated data, as it deems appropriate. These survey results are confidential, and for
members’ internal use only. The survey is copyrighted by the Investment Company Institute,
all rights reserved. No part of the survey document may be reproduced, stored in a retrieval
system, or transmitted in any form or by any means – electronic, mechanical, photocopying,
recording, or otherwise – without prior permission.
We would like to extend our thanks to Charlie Hawkins of PNC Financial Services, who
led this project, as well as to the ICI TAAC members who participated on the CIP Survey task
force. We would also like to thank those fund complexes that participated in the survey. If you
have any questions or comments, please contact the undersigned at 202-326-5930 or at
kjoaquin@ici.org.
Kathleen C. Joaquin
Director – Operations & Distribution
Attachment (in .pdf format)