Memo #
31279

Updated Social Code Categorization Matrices for Customer Due Diligence and Money Market Funds
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[31279]

July 13, 2018 TO: ICI Members
AML Compliance Working Group
Bank, Trust and Retirement Advisory Committee
Broker/Dealer Advisory Committee
Compliance Advisory Committee
Money Market Funds Advisory Committee
Money Market Working Group
Operations Committee
SEC Rules Committee
Small Funds Committee
Transfer Agent Advisory Committee SUBJECTS: Anti-Money Laundering
Compliance
Distribution
Money Market Funds
Operations
Recordkeeping
Transfer Agency RE: Updated Social Code Categorization Matrices for Customer Due Diligence and Money Market Funds

 

ICI has updated the social code categorization matrices for customer due diligence (CDD) and money market funds.

The attached matrices, each developed by ICI industry working groups to assist with account categorization activities in response to final rulemaking for each area, now include new social code numbers and descriptions introduced by the National Securities Clearing Corporation (NSCC), effective July 9, 2018.[1] The new social codes (96-98; A0-A4) as well as related account categorizations, are described within each matrix.

Specific to the CDD matrix, social code 84 (Investment clubs; unions; unincorporated association; miscellaneous organizations) was recategorized as a “non-legal entity customer” in response to Financial Crimes Enforcement Network (FinCEN) Frequently Asked Questions issued April 3, 2018.[2]

Please direct any questions or comments on either matrix to the undersigned (jeff.naylor@ici.org, 202-326-5844) or Joanne Kane, Director, Operations and Transfer Agency (joanne.kane@ici.org, 202-326-5850).

 

Jeff Naylor
Director, Operations and Distribution

 

Attachment No. 1

Attachment No. 2

endnotes

[1] NSCC is a wholly-owned subsidiary of The Depository Trust and Clearance Corporation (DTCC). Please refer to DTCC Important Notice A8531 for additional information on the new social codes.

[2] Reference https://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf, question 22, for additional information.