Customer Identification Program

Be it resolved, that it is the policy of the Bank of Hartington to maintain maximum compliance with the Customer Identification Program pursuant to Section 326 of the USA Patriot Act. The Board of Directors appoints Cheryl Pinkelman, Assistant Vice President of Operations as the officer to oversee the Customer Identification Program of the Bank.

This policy shall apply to all persons who become customers of the Bank of Hartington after the date of the adoption of this policy, which is July 3, 2003. Persons who have had a relationship with the Bank of Hartington prior to July 3, 2003 will not be subject to the requirements of this policy providing we are reasonably assured we know the true identity of the customer.

It is the policy of the Bank of Hartington to obtain identifying information about every customer. If the customer is an individual the bank will obtain the following:

• Individual’s name
  
• Individual’s date of birth
  
• Individual’s residence address (physical address)
  
• If the individual is a U.S. person, the individual’s social security number. If the individual is a non-U.S. person at least one of the following: U.S. taxpayer identification number; a passport number and country of issuance; an alien identification card number and country of issuance or other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

If the customer is not an individual, the bank will obtain the following:

• Customer’s name
  
• Address of the customer’s principal place of business, local office or other physical location
  
• If the customer is a U.S. person, an employer identification number or if the person does not have or is not required to apply for an employer identification number, the social security numbers of the principals or the person. If the customer is a non-U.S. person, a U.S. taxpayer identification number or if the customer is not required to have a U.S. taxpayer identification number, a taxpayer identification number issued by the country of the customer’s residence

It is the policy of the Bank of Hartington that it will not establish an account relationship with an individual until the required information about the individual is obtained. If the person is a newly formed legal entity and does not have a taxpayer identification number, but provides evidence that a taxpayer identification number has been applied for then the account may be opened. In such case, the customer will be required to provide a taxpayer identification number within eight weeks of the date that the account is opened. If the taxpayer identification number is not so provided, the account shall be closed.

It is the policy of the Bank of Hartington to verify the identity of every customer at the time of application and prior to opening the account. The Bank of Hartington shall adopt procedures for verifying the identity of its customers that are sufficient to enable the bank to form a reasonable belief that it knows the true identity of the customer. The procedures shall be based on the risk presented by the various products and services that the Bank of Hartington offers, the nature of the customer whose identity is being verified and the business relationship with the Bank of Hartington that the customer is seeking.

Independent testing for compliance to the requirements of the Customer Identification Program will be completed annually.

Training will be provided to appropriate personnel.

It is the policy of the Bank of Hartington to adhere to the following record keeping requirements:

1) All identifying information (name, date of birth, address, tax identification number) must be maintained for 5 years after the account is closed. This information could be stored electronically.

2) The following must be retained for five years after the record is created:

• A description of the type of any document relied on for verification (driver’s license, passport, etc.) including: the identification number on the document; place of issuance (country, state, etc.) date issued (if applicable) expiration date
  
• A description of any non-documentary methods used and the result (credit report, contacting customer, etc.);
  
• Description of how any substantial discrepancies were resolved

It is the policy of the Bank of Hartington to provide customers with adequate notice that we are requesting information to verify their identities. This notice can be given orally or in a manner reasonably designed to ensure that the customer is able to view the notice.

It is the policy of the Bank of Hartington to determine whether the customer appears on any list of known or suspected terrorist organization within a reasonable period of time after the account is opened, or earlier, if required by Federal law or regulation.