AFCO's Customer Identification Program (CIP)

USA PATRIOT ACT — "Know Your Customer" Requirements - FAQs

Important Information You Should Know About Opening an Account

In accordance with the USA PATRIOT ACT, federal law requires AFCO to implement a Customer Information Program (CIP) aimed at obtaining, verifying and recording verificable information on customers seeking to open an account for the purpose of obtaining a loan.

We appreciate your business and continued support as we move forward with our CIP program for compliance with the USA PATRIOT Act.  If you have questions about AFCO's CIP program, please contact our CIP Team at or by telephone at 844-385-7918.

What is CIP?

The Customer Identification Program (CIP) is a government-required program that requires AFCO and other lenders to identify anybody seeking to open an account.  By federal law, AFCO must verify the identity of all customers and retain client information.
The federal government requires lenders such as AFCO to implement a CIP program for compliance with the USA PATRIOT ACT, which was enacted as part of the effort to fight terrorism and money laundering. The PATRIOT ACT was made law as an amendment to the Bank Secrecy Act following the tragic events of Sept. 11, 2001.

The USA PATRIOT ACT stipulates that banks and financial services companies like AFCO are compelled to obtain what is known as “Personally Identifiable Information” about individuals and entities doing business with them. Section 326 of the USA PATRIOT ACT requires financial institutions to implement procedures that enable them to form a reasonable belief that they know the true identity of the client.

More specifically, Section 326 requires “banks, savings associations, credit unions and certain non-federally regulated banks to have a Customer Identification Program (CIP).  The program's aim is to identify anybody seeking to open an account, verify the identity of that individual or entity, and retain client information.

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CIP Process and Program Enhancements

We have made several system and program enhancements aimed at making it easy for everyone to be in compliance with this program, including:

    1. Providing a CIP Disclosure Addendum to all PFAs requesting the insured’s information
    2. Creating new CIP data entry fields in our quoting applications
    3. Utilizing third-party data providers to provide missing CIP data, where possible
    4. A direct-mail campaign to insureds asking for their CIP information

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Agent/Broker Requirements: I received a "PFA Incomplete Notice" – What do I do?

  • Based upon your feedback, and to further improve our CIP process, we added a new “Incomplete Addendum” for select clients and made the original “CIP Disclosure Addendum” more dynamic by displaying data provided to us at the time of the quote. This should make it easier for you to know what information we have and what is still needed from you and your insured.
  • The new "CIP Incomplete Addendum – “Important Notice to the Agent(see example below) will be included with any PFA package only when all the required information has not been provided at the time of the quote. If all the information was captured at the time of the quote, this new addendum will not generate as part of the Premium Finance Agreement (PFA). 
  • If only some of the required information was provided, both the Incomplete Addendum and the Disclosure Addendum will appear as part of the PFA. The latter (Disclosure Addendum) will be populated with any data previously provided. Only missing data fields will remain blank.
  • The attached example illustrates a transaction where the agent provided an insured's physical address and their Social Security Number but failed to provide the insured's DOB. Notice the DOB field is blank – but it still needs to be filled in by the either agent/broker or the insured to complete the acceptance and funding process.


Shown above: Example of "CIP Incomplete Addendum – Important Notice to Agent"

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What sort of information is required from insureds?

For compliance with the stipulations of the USA Patriot Act, we are required to obtain and verify the following: 

    • The insured’s legal name in full
    • The insured’s physical-location address (not merely the P.O. Box Number or registered agent address)

           and ...

      • For commercial borrowers: Your Tax Identification Number (TIN)
      • For sole proprietors or individual consumers: Your Federal Employer Identification Number (FEIN) and/or Social Security Number (SSN) with Date of Birth (D.O.B.).

This information must be provided to AFCO to fund your insurance premiums and finance your loan.  The required information may be provided either at the time of a request for a finance quote, during the initial loan period, or when the loan comes up for renewal.  You may see a copy of the addendum that is attached to your Premium Finance Agreement, as shown below:

Please complete any blank spaces and forward it to AFCO as requested on the addendum.  We may not be able to process your application for premium financing unless we receive the information required by law.

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If an Insured's Identity Cannot Be Verified ...

We may not be able to open an account for you or continue to fund your policy when it comes up for renewal.  We thank you for your patience and hope that you will support the overall efforts to deny terrorists and money launderers access to America's financial system.

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Do insureds have to supply this information every year they finance with AFCO?

Not necessarily. As long as the information submitted with the initial application passes the government’s CIP requirements, the information provided with the initial finance request will remain valid as long as there are no substantive changes such as a change of address.

    • IMPORTANT NOTE:  Because federal law requires us to take steps to verify the identity of each person or entity seeking to do business with us, we may not be able to process your loan application unless we receive the information required by law.

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Does AFCO ever contact an insured directly, if the required information is not provided by the insurance agent or broker?

If the required information is not provided by the agent/broker, one of AFCO's CIP Team associates may contact you or your insurance agent to obtain the required information. In some cases, insureds may receive a letter in the mail from AFCO, requesting they provide the required information.

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If an agent or borrower seeks to provide the required information over the telephone, will AFCO accept that information?


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I do business in Canada. Is CIP a requirement for CAFO Premium Installment Contracts (PICs) and cross-border transactions?

In Canada, Premium Finance Agreements (PFAs) for insureds conducting business in the United States will include the “USA Patriot Act Customer Identification Program (CIP) Disclosure Notice” for compliance with U.S. Federal law (The USA PATRIOT ACT), which requires CAFO and/or its affiliate AFCO to obtain, verify and record information about anybody, including insureds, who opens an account with AFCO/CAFO or establishes a relationship with our company in the U.S.

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What is the difference between “establishing a relationship” and “opening an account”?

An entity or an individual could seek to establish a relationship with AFCO without getting to the point of actually opening an account with us.

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How will you protect my information?

To protect client information from unauthorized access and use, we implement structured security measures that include technology systems and computer safeguards, secured files and buildings, and systematic processes and procedures. All measures comply with federal law.

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Questions? Contact Our CIP Team

We appreciate your business and continued support as we move forward with our CIP program for compliance with the USA PATRIOT Act.  Should you have any questions, please let us know by contacting our CIP Team at or by telephone at 844-385-7918.

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