Bom a129 b

08/01/16 A-129B
Account Opening-Business/Client Identification Program
(CIP)
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Last Revised 08/01/16 A-129B
Last Reviewed 12/01/15 Account Opening-Business/Client Identification Program
(CIP)
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A-129B – Account Opening-Business/Client Identification Program (CIP)
Section I - General.......................................................................................................................................2
PURPOSE ..............................................................................................................................................2
BACKGROUND......................................................................................................................................2
USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools
REQUIRED TO INTERCEPT AND OBSTRUCT TERRORISM ACT) ...................................................2
CLIENT IDENTIFICATION PROGRAM (CIP) – KNOW YOUR CLIENT...............................................3
ADDITIONAL KNOW YOUR CUSTOMER (KYC) INFORMATION ……………………………………...6
VERIFYING THE IDENTITY OF THE BUSINESS OWNER ..................................................................6
UNITED STATES POSTAL SERVICE (USPS) ADDRESS VERIFICATION ........................................7
ELECTRONIC CLIENT IDENTIFICATION PROGRAM (E-CIP)............................................................7
CIP DISCREPANCY FOUND AT ACCOUNT OPENING ......................................................................8
CIP DISCREPANCY FOUND AFTER ACCOUNT OPENING...............................................................8
IDENTIFICATION TYPES ......................................................................................................................8
CREDIT BUREAU INQUIRIES/RED FLAG ALERTS............................................................................8
SOCIAL SECURITY NUMBERS & CHEXSYSTEMS REPORTS .........................................................9
Section II – Existing Clients .......................................................................................................................9
Section III – Restricted/Prohibited Client Relationships .......................................................................10
EMBASSY/CONSULATES/FOREIGN GOVERNMENTS ...................................................................10
FOREIGN MONEY SERVICES BUSINESS/(MSB) .............................................................................10
MONEY SERVICES BUSINESS (MSB)...............................................................................................10
PRIVATE INVESTMENT COMPANIES (PIC’S) ..................................................................................10
Section IV – Potential High Risk Clients .................................................................................................10
AUTOMATIC TELLER MACHINE (ATM)/INDEPENDENT SALES ORGANIZATION (ISO) .............10
HIGH RISK BUSINESS........................................................................................................................10
REMOTELY CREATED CHECK (RCC) ..............................................................................................11
UNLAWFUL INTERNET GAMBLING ENFORCEMENT ACT (UIGEA) – REGULATION GG...........11
OTHER HIGH RISK INDICATORS ......................................................................................................11
Section V - Accounts With Special Conditions ......................................................................................12
AGENCY ACCOUNTS .........................................................................................................................12
CHARITABLE/MEMORIAL ACCOUNTS/FUND RAISING ACCOUNTS............................................12
CLERK OF COURT..............................................................................................................................12
COLLATERAL RESERVE ACCOUNTS..............................................................................................13
DEPOSIT ACCOUNT CONTROL AGREEMENT (DACA) ..................................................................14
DOING BUSINESS AS (DBA) ACCOUNTS........................................................................................14
ESCROW (AGENT) ACCOUNT...........................................................................................................15
FOREIGN/INTERNATIONAL ACCOUNTS..........................................................................................15
GIRL SCOUTS/BOY SCOUTS/CLUBS/TROOPS...............................................................................16
HEALTH INSURANCE PORTABILITY ACCOUNTABILITY ACT (HIPAA)/HEALTH INFORMATION
TECHNOLOGY FOR ECONOMIC AND CLINICAL HEALTH ACT (HITECHA).................................16
LIMITED LIABILITY COMPANY (LLC) ARTICLES OF ORGANIZATION .........................................16
PUBLIC FUND ACCOUNTS ................................................................................................................17
TRUST ACCOUNTS.............................................................................................................................17
Section VI – Resolution and Agreement for Deposit Account .............................................................17
Section VII – Authorization Agreement for Deposit Account (applicable to foreign/international
business accounts only)....................................................................................................................18
Section VIII - Signature Card SmartScan Print/Documents ..................................................................18

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Section IX - Supply Requirements...........................................................................................................19
Section X - Account Opening-Procedures..............................................................................................20
THE SIX STEP ACCOUNT OPENING/BUSINESS .............................................................................20
BUSINESS CLASSIFICATION AND INDUSTRY CODE ....................................................................20
BUSINESS RECOVERY ......................................................................................................................21
LIST CHECKING (CLIENT CENTRAL “BANKING ELIGIBILITY” ERROR MESSAGE) ..................21
CLIENT CENTRAL QUESTIONS AND ANSWERS PAGE.................................................................21
CIF/AIF STANDARDS..........................................................................................................................21
BB&T PHONE24®................................................................................................................................21
INITIAL DEPOSIT.................................................................................................................................22
CHECKING/SAVINGS STATEMENT ..................................................................................................22
TELECOMMUNICATIONS DEVICES FOR THE DEAF (TDD) SERVICE ..........................................22
Section XI - Introduction of New Clients.................................................................................................22
Section XII – Revised Resolution And Agreement For Deposit Account, Authorization Agreement
For Deposit Account, Signature Card and Commercial Deposit Processing Agreement (Night
Depository) ..........................................................................................................................................22
ADDITIONS/DELETIONS OF CERTIFYING OFFICERS/DESIGNATED INDIVIDUAL SIGNERS ....22
Section I - General
PURPOSE
To outline procedures for opening business Checking, Savings and CD (Certificate of Deposit) accounts.
BACKGROUND
USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools Required
to Intercept and Obstruct Terrorism Act)
USA PATRIOT Act is an amendment to the Bank Secrecy Act that was signed by President Bush on
October 26, 2001. One (1) of the primary purposes of the USA PATRIOT Act is to “increase the strength
of the United States measures to prevent, detect, and prosecute international money laundering and the
financing of terrorism”.
OFAC (Office of Foreign Assets Control)
OFAC is a division of the US Department of the Treasury. It administers a series of laws that impose
economic sanctions and trade embargoes against hostile targets, including designated foreign countries,
individuals, and entities, to further US foreign policy and national security objectives.
Additional information on how to comply with OFAC is located in BOM section O-500 - Office of Foreign
Assets Control (OFAC).
PROCEDURES
Refer to the Bank Secrecy Act Policy to view the Policy.

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CLIENT IDENTIFICATION PROGRAM (CIP) – KNOW YOUR CLIENT
Based on passage of the 1992 Annunzio-Wylie Money Laundering Act (Pub. L. No. 102-550); Financial
Institutions were encouraged to implement a "Know Your Client" policy. With the passage of the USA
PATRIOT Act in 2001, financial institutions were required to implement a Client Identification Program
(CIP.) The CIP is a means to identify, verify, and retain information on new account relationships, and
enhances BB&T's existing "Know Your Client" policy.
BB&T must be satisfied that our records contain the necessary information concerning the true identity of
the person for whom the transaction is conducted in order to complete a Currency Transaction Report
(CTR) and Suspicious Incident Report (SIR), if required. The SIR must be filed within twenty-four (24)
hours of detection/notification of the potentially suspicious activity. Refer to BOM section S-947 -
Suspicious Incident Reporting (SIR) to view additional procedures.
To ensure that you "Know Your Client", accounts must be opened with a valid Tax Identification Number
(TIN) (i.e., social security number (SSN) for Sole Proprietor or employer identification number (EIN) for
business entity). It is the policy of BB&T that we will not open accounts for clients who cannot provide a
SSN/EIN or any of the additional three (3) pieces of information required as dictated in the “REQUIRED
INFORMATION FOR BUSINESS ENTITY” category in this publication. The client record; Customer
Information File (CIF) must always have a physical address, not a PO Box.
Foreign established entities are required to complete one (1) of the W-8 forms. Along with the completed
form W-8, foreign entities are required to provide document(s) that substantiate that they are
organized/incorporated outside the U.S. Usually, they would complete the W-8 BEN. Refer to BOM
section I-968 - IRS/Non Resident Alien (NRA) Documentation to view instructions on completing the W-
8BEN and additional procedures. There are also forms W-8ECI, W-8EXP and W-8IMY. Should the client
need a form other than the W-8BEN, contact IRS/Regulatory Compliance at (910) 272-4270. For
additional information regarding Foreign entities, refer to the FOREIGN/INTERNATIONAL ACCOUNTS
category of this publication.
When opening new deposit accounts or assisting in the receipt of additional deposits received from or
withdrawals being sent to countries identified by the United States Treasury's Financial Crimes
Enforcement Network (FinCEN) as having inadequate counter money laundering programs, staff should
understand the legitimate business purpose behind the transaction. Staff should give enhanced scrutiny
to the transactions or banking relationships that do not involve established, and adequately identified and
understood, commercial or investment enterprises. Nothing contained in these advisories is intended to
curtail legitimate business transactions involving these countries, or businesses organized or domiciled,
or persons maintaining accounts in these countries.
Refer to BOM section S-947 - Suspicious Incident Reporting (SIR) for instructions on accessing the list of
countries identified by FinCEN that have insufficient counter money laundering programs and information
regarding the completion of a SIR for all transactions that do not appear to have a legitimate business
purpose using the dollar thresholds and guidelines.
Should an associate have additional questions about how to complete the SIR; contact the Area
Operations Officer (AOO) Hub, AOO Consultant, AOO Compliance, AOO Branch Team Leader (AOO
BTL), Regional Branch Operations Manager (RBOM) or the Regional Investigator.

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OFFSITE CLIENT CONTACT
When visiting with potential clients away from Bank facilities, the Business Service Officer (BSO), Market
President (MP), Regional President (RP), Market Leader (ML) or other associate should complete the
following BB&T documents:
 New Business Account Information Sheet;
 Resolution and Agreement for Deposit Account or Authorization Agreement for Deposit Account
(applicable to foreign/international accounts); and
 BB&T signature card.
When the client signs the signature card, he/she will verify the accuracy of the information that has been
recorded on the records of the Bank.
Refer to Section X category for a list of other required supplies needed to establish business accounts
offsite.
The completed documents listed above should then be given to a branch associate to key the new
account on Client Central.
It is recommended that the branch associate who opens the account should obtain the signature of the
approving officer on the signature card. The approving officer will sign (first initial and last name) in the
"Approved By" field on the signature card.
NOTE: Associates must not accept deposits outside of the branch due to Federal Deposit
Insurance Corporation (FDIC) restrictions.
REQUIRED INFORMATION FOR BUSINESS ENTITY
Business documentary verification is the use of documents that show the existence of the entity. The
USA PATRIOT Act requires the following information be obtained to establish an account:
1. Client’s Legal Name (as it appears on the identification provided by the client).
2. Physical Address – PO Box is not acceptable except for mailing address.
3. EIN (for US Entity/Taxpayer Identification Number (TIN) or other Government issued number for a
Non US Entity). Social Security Number may be accepted for a sole proprietorship.
4. Identification Information.
If the client does not have the required “Information”, refuses to provide the required “Information”, or
presents information that contains discrepancies (see explanation for discrepancies below) that cannot
be resolved; DO NOT OPEN THE ACCOUNT.
A new business client must provide a TIN and present a valid form of identification (e.g., a Business
License or Certificate of Existence, etc.). The form of identification used is to be documented on the
generated signature card.

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The documents listed below are intended to be used as a guide for client identification and is not intended
to be all inclusive. Documents are obtained as follows:
 Articles of Incorporation - Normally prepared by an Attorney and filed with an appropriate
government agency.
 Business License – Issued and registered by an appropriate government agency; local municipality
or county where the business is being conducted.
 Certificate of Existence - Issued by an appropriate government agency.
 Certificate of Foreign Corporation – If the business’s primary operation is located in a different
state, then a Certificate of Foreign (out-of state) Corporation to conduct business can be accepted.
 Certificate of Good Standing - Issued by an appropriate government agency. If the Certificate of
Good Standing indicates that the client is not in good standing, BB&T should not open the
account until the situation is remedied.
 DUNS # (Date Universal Numbering System) - Issued by Dun & Bradstreet.
 Secretary of State ID – Issued by Secretary of State (where applicable).
 Trust Agreement* – BB&T does not read Trust Agreements.
*NOTE: Branch associates will establish the accounts after completion of the BB&T Trust
Certification.
The applicable website may be used to identify and verify the existence of the business in lieu of the
actual paper documents.
Applicable websites:
www.sos.alabama.gov/ AL Select “Business Entity Search
Options”
Choose the appropriate menu item
pivs.dcra.dc.gov/ (DC) Select appropriate “Search
By:” category
Enter the appropriate information
based on selected menu item
www.sunbiz.org (FL) Select “Look up a Business
Name”
www.sos.ga.gov/ GA Select “Business Search” Enter the name in the “Business
Name” field
www.in.gov IN Select “Business &
Agriculture”
kentucky.gov KY Select “Menu”, “Business” Choose the appropriate menu item
www.md.gov/ MD Select “Business” Choose the appropriate menu item
www.njportal.com (NJ) Select “Search Trade Name
and Trade/Service Mark”
www.nc.gov/ NC Select “Business &
Employment”
www2.sos.state.oh.us (OH) Enter “Business Name” Click “Search” or Choose the
appropriate “Business” Search menu
item
www.corporations.pa.gov/ (PA) Enter “Business Entity
Name/ID”
Choose the appropriate “Type of
Search”
www.scsos.com/ SC Select “Business Filings” Select “Search Business Filings”
www.tn.gov/ TN Select “Business” Choose “Search Corporations and

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LLCs”
www.window.state.tx.us/ TX Select “Business” Choose “Franchise Account Status”
www.virginia.gov/ VA Select “Business” Choose the appropriate menu item
www.wv.gov/ WV Select “Business” Choose the appropriate menu item
Documents that are required by BB&T, such as Resolution and Agreement for Deposit Account,
Authorization Agreement for Deposit Account (Foreign/International Business accounts only), BB&T Trust
Certification or BB&T Escrow Agent Certification are not affected by CIP. The client must still complete
BB&T’s documents according to each line of business procedures.
ADDITIONAL KNOW YOUR CUSTOMER (KYC) INFORMATION
The following two (2) pieces of additional information are important to our KYC efforts and attempts to
collect this information should be made when establishing an account:
1. Telephone Number of the Business, and
2. Business Type/Organization.
VERIFYING THE IDENTITY OF THE BUSINESS OWNER
Information collected about the business owner is called identifying information. If the business is a
new business or the documentation about the business is unfamiliar to the branch associate, additional
information identifying ownership would be required. Refer to sub-section titled Social Security Numbers
& ChexSystems Report for instructions on when to request a Social Security Number.
NOTE: Branch associates must take appropriate steps to authenticate that the person is who
he/she claims to be and that he/she has the authority to sign or conduct transactions
on behalf of the business. Before opening a new deposit account for an existing
client, branch associates must verify the existing business resolution (i.e., BB&T
Resolution And Agreement For Deposit Account, BB&T Authorization Agreement For
Deposit Account, the business corporate resolution) currently on file to ensure the
person opening the account is a designated representative.
When verifying the identity of the owner or a signer through the use of a government-issued document, it
is called documentary verification. Examine the document to ensure that it is not expired, check for
obvious alterations, compare the address and date of birth to the information provided by the client,
compare the picture to the client; when applicable, and compare the signatures.
If unfamiliar with the ID presented, refer to the I.D. Checking Guide for the United States and Canada. If
there is still uncertainty or validity of the document is questionable, refer to the ML, Branch Banker Team
Leader (BBTL), AOO, AOO Consultant, AOO Compliance or AOO Branch Team Leader (AOO BTL) for
assistance and approval.
NOTE: Some state and federal documents are issued without a picture. Review the current
I.D. Checking Guide for the United States and Canada to determine proper description
of the item used for identification that is absent of a picture.

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If documents are unavailable or unfamiliar, then a non-documentary verification method may be used to
support or enhance the documentary method. A non-documentary method is one (1) in which we verify
the client's identifying information through means other than a government-issued document. Examples
of non-documentary verification:
 Using a third party reporting agency (i.e., ChexSystems, credit bureau or LexisNexis).
UNITED STATES POSTAL SERVICE (USPS) ADDRESS VERIFICATION
Refer to Deposit Account Policy to view the Policy.
Refer to Client Information File (CIF) Address Standards to view the Standards.
Branch associates must ensure that the address information provided by the client includes the correct
street number, street name, city, state and zip code when the client's address is keyed on Client Central.
ELECTRONIC CLIENT IDENTIFICATION PROGRAM (E-CIP)
Refer the Bank Secrecy Act Policy to view the Policy.
E-CIP allows the branch associate to perform a verification of identity when there are no other acceptable
forms of ID available. After the branch associate has gathered the client’s business name, business
physical address, and TIN/EIN. Click the “Send for Verification” option listed under Primary ID within
Client Central. Once the client has been properly identified using the “Send for Verification”, proceed with
the account opening process as usual.
The E-CIP involves sending a real-time request to an outside vendor to perform an electronic
identification of the client. This feature allows the branch associate to perform a verification of identity -
only when opening a new account - when there are no other preferred forms of ID available. This option
may be used only after you have attempted to obtain preferred forms of ID when opening the account.
NOTE: The E-CIP “Send for Verification” option is not to replace the branch associate’s due
diligence in attempting to obtain proper ID from the client. Branch associates should
always attempt to obtain preferred ID before attempting to E-CIP a client. There is an
additional cost to the bank when this option is used. Due to the additional cost, the
use of this option will be monitored.
Branch associates can refer to CIP Client Identification Quick Reference Guide to view training material
relating to the E-CIP process.
Follow-up on information provided during the account opening process within twenty-four (24) hours to
include the following steps:
 It is recommended to drive by the business location, and
 Perform a reverse look up from Yellow Pages. Refer to the Yellow Pages to perform a search.
 Perform a Google search of the address, business name and business owner and provide client
information to the ML for a follow-up site visit.

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NOTE: The branch associate is not required to verify the identity of a government entity (e.g.,
City of Wilson, Commonwealth of Virginia, etc.).
CIP DISCREPANCY FOUND AT ACCOUNT OPENING
CIP Discrepancy occurs when information provided by the client does not agree with the information on
the identification document provided by the client. When the branch associate identifies a discrepancy,
the discrepancy type must be indicated: Name, Address, TIN/EIN. Any discrepancy must be
documented on the Client Central “Primary Identification” screen.
Should the branch associate select “No” to the following field, “Does the ID match the information
provided by the client?”, the branch associate will be required to complete the applicable fields indicating
the information that does not match as well as the explanation for the difference(s).
Example: Client presently operating business from home garage will move to new location at completion
of new building (estimated to be 10/05/2015).
If a CIP discrepancy cannot be fully explained, refer to the ML, BBTL, AOO, AOO Consultant, AOO
Compliance or AOO BTL for assistance and approval.
CIP DISCREPANCY FOUND AFTER ACCOUNT OPENING
In the event that a deposit account or safe deposit box is opened with a discrepancy, the account
opening officer will have up to forty-five (45) days from the account opening date to resolve the
discrepancy. If the issue is not resolved within the allowed time frame of forty-five (45) days, a
review by CIP Management of the account/safe deposit box will take place and account/safe
deposit box closing procedures will be started.
IDENTIFICATION TYPES
Branch associates are required to view all identification. Do not select or key any identification without
having viewed the documentation. Opening accounts in this manner poses a potential exception to
federal regulations.
All information must be keyed on CIF. All clients must be present.
Some state and federal documents are issued without a picture. Review the current I.D. Checking Guide
for the United States and Canada to determine proper description of the item used for identification that is
absent of a picture.
If the client does not have proper identification, the account cannot be opened. The Regional CIP
Contact or AOO Hub is available to assist with situations when proper identification does not seem to be
readily available. The Regional CIP Contact or AOO Hub can also work with CIP Management to obtain
proper identification from the client.
CREDIT BUREAU INQUIRIES/RED FLAG ALERTS

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Refer to Credit Bureau/Consumer Reporting Standards to view the Standards.
The credit bureau may be used to approve an individual as an account owner and identify referral
opportunities. Only certain business class codes systematically go through the credit bureau. The credit
bureau may return certain alerts, notifications, or warnings that the bank must consider Red Flags. A
Red Flag is a pattern, practice, or specific activity that indicates the possible existence of identity theft.
An account can be declined due to Red Flag alert(s) from the credit bureau.
If a Red Flag Alert is received, the branch associate must select the appropriate override reason from
Client Central. Refer to the Red Flag Alerts Quick Reference Guide to view Red Flag alerts and
determine appropriate override reason. If approval is required, “ML/AOO Approval” will be selected in
Client Central. The associate must contact ML/BBTL/AOO/AOO Compliance/AOO Consultant/AOO
BTL/RBOM for approval. Once approval has been granted, associate will enter approver’s User ID in
Client Central. A system generated email will be sent to the approver. These emails must be monitored
by approving officer who is responsible for correcting the account and/or client if override was completed
without proper approval. A CIF Comment will automatically be created, based on the override reason
selected to document the Red Flag override.
If a business owner is declined due to his/her credit bureau or ChexSystems information, the Statement
of Denial form will automatically print. The printed form should be given to the client.
Refer to Forms and Examples section C-370 - Credit Bureau/ChexSystems to view sample form.
SOCIAL SECURITY NUMBERS & CHEXSYSTEMS REPORTS
Refer to Business Deposit Account Opening Standards to view the Standards.
Section II – Existing Clients
An existing Client is an individual that has maintained an active, ongoing CIP applicable account
relationship with the Bank prior to 10/1/03.
CIP Identification information, in most cases will be systematically populated in the CIF record for
business (Commercial) clients meeting the BB&T definition of an “Existing Client”. Business clients that
have been identified in this manner will not be required to present a driver’s license or other form of ID
when establishing a new account, as long as they maintain an ongoing relationship with BB&T.
Branch associates are responsible for ensuring the existence and accuracy of all identifying information
for existing clients when adding new accounts. Any missing or incorrect information must be corrected
prior to adding the new account.
It is still the responsibility of the branch associate to ensure that he/she "Know Your Client", if unfamiliar
with the “Existing Client” relationship, request proper identification.

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NOTE: Use the TLC - Profiling an Existing Personal and Business Quick Reference Guide as a
tool for profiling suggestions.
Section III – Restricted/Prohibited Client Relationships
EMBASSY/CONSULATES/FOREIGN GOVERNMENTS
BB&T will not pursue nor knowingly open client relationships with Embassies, Consulates, Foreign
Governments or clients they know are affiliated with these types of entities (e.g., Foreign Government
Schools, Foreign Organizations, Foreign Relief Funds, etc.).
Branch associates who become aware of existing client relationships within his/her region should
immediately notify the AOO, AOO Consultant, AOO Compliance, AOO BTL or RBOM.
FOREIGN MONEY SERVICES BUSINESS/(MSB)
Refer to BOM section M-323 - Money Services Business to view procedures.
MONEY SERVICES BUSINESS (MSB)
Refer to BOM section M-323 - Money Services Business to view information related to MSB accounts.
PRIVATE INVESTMENT COMPANIES (PIC’S)
BB&T will not pursue nor knowingly open client relationships for Private Investment Companies (PIC’s).
PIC’s are foreign shell companies (no physical presence), incorporated primarily in offshore secrecy or
tax haven jurisdictions. Associates having questions regarding the identification of a PIC should call
BSA/AML EDD Management at (252) 296-0784.
Branch associates who become aware of existing PIC relationships within his/her region should
immediately notify the AOO, AOO Consultant, AOO Compliance, AOO BTL or RBOM and BSA/AML EDD
Management at (252) 296-0784.
Section IV – Potential High Risk Clients
AUTOMATIC TELLER MACHINE (ATM)/INDEPENDENT SALES ORGANIZATION (ISO)
Refer to ATM-ISO Policy and Procedures located on the Bank Secrecy InSite page under Forms and
Procedures for additional documentation. Privately owned ATM businesses and ISO companies are
particularly susceptible to money laundering and fraud.
HIGH RISK BUSINESS
Refer Deposit Account Policy to view the Policy.

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Refer to High Risk Business Standards to view the Standards and to see a list of “Definitions”.
Prior to opening the account refer to BOM section T-116 - Tele/Web Marketer Businesses to view
additional procedures.
REMOTELY CREATED CHECK (RCC)
A Remotely Created Check (RCC), also known as a paper draft, demand draft or a tele-check, is a
check created by a seller with a buyer's checking account number on it, but without the buyer's signature.
In place of the signature, the check generally has verbiage such as "authorized by drawer (the buyer)” or
bears the client’s printed or typed name. The seller deposits the check into his/her bank account, and the
check then clears out of the buyer's account.
RCCs are frequently used to purchase items over the phone, from telemarketers, or via the web. The
checks also allow consumers to pay monthly bills by having them debited automatically out of his/her
accounts, rather than having to write a new check each month. RCCs are frequently used by consumers
instead of card payments, and large companies also commonly use them. RCCs may be viewed as a
substitute for ACH debits and card payments.
Refer to Remotely Created Checks (RCCs) Quick Reference Guide to view additional documentation.
Follow other new account opening procedures as outlined in this section.
UNLAWFUL INTERNET GAMBLING ENFORCEMENT ACT (UIGEA) – REGULATION GG
Regulation GG (12 CFR Part 233) implements the Unlawful Internet Gambling Enforcement Act of 2006;
this implementation was enacted at BB&T on June 1, 2010. The act prohibits any person engaged in the
business of betting or wagering (as defined in the act) from knowingly accepting payments in connection
with the participation of another person in unlawful Internet gambling. Such transactions are termed
“restricted transactions.” The act generally defines “unlawful Internet gambling” as placing, receiving, or
otherwise knowingly transmitting a bet or wager by any means which involves the use, at least in part, of
the Internet where such bet or wager is unlawful under any applicable federal or state law in the state or
tribal lands in which the bet or wager is initiated, received, or otherwise made.
Refer to the Unlawful Internet Gambling Enforcement Act (UIGEA) Reg GG Quick Reference Guide to
view additional procedures.
Refer to the Unlawful Internet Gambling Enforcement Act Certification to access the certification.
Refer to Forms and Examples section A-129B to view a sample certification.
OTHER HIGH RISK INDICATORS
Identifying high risk businesses and geographic locations that may pose a higher risk is essential to
BB&T’s BSA/AML compliance program. BB&T should understand and evaluate the specific risks

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associated with doing business in, opening accounts for customers from, or facilitating transactions
involving certain businesses and geographic locations.
Refer to Potential High Risk Indicators on the BSA/AML InSite page for information on potential types of
high risk businesses and geographic locations.
Section V - Accounts With Special Conditions
AGENCY ACCOUNTS
AOO BTL or RBOM should consult with the BB&T Legal Department for additional assistance.
BB&T – ENTERPRISE OWNED ACCOUNTS
Refer to BB&T Enterprise Owned Deposit Accounts Policy to view the Policy.
Refer to BB&T Enterprise Owned Deposit Accounts Standard to view the Standards and the required
Enterprise Owned Deposit Account Approval Eform.
CHARITABLE/MEMORIAL ACCOUNTS/FUND RAISING ACCOUNTS
CLERK OF COURT
The Clerk of Court Code must be completed by entering the five (5) digit numeric code following the CSC
code on Client Central. The code format is as follows:
CSC12345
Follow procedures as outlined below for the applicable account requested at new account opening:
Clerk of Court Demand Deposit (DDA)/Savings (SAV) Accounts
Product Type 404- Clerk of Court Savings accounts only require the code to be added at new account
opening. When the code is not known, contact DDA/SAV/HSA Administration, Lumberton, NC at (910)
272-4153 for the CSC code. This is necessary to ensure that the accounts are coded and can be
properly reported.

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NOTE: Client Central will not allow the Product Type 404 account to be keyed without the CSC
code.
All other product types will require completion of the DDA/SAV/HSA Maintenance Request at new
account opening. When completing the e-form, specify the following information in the field TYPE OF
MAINTENANCE: “Add Clerk of Court Code in the User Area – CSCXXXX and include the County name”.
This is necessary to ensure that the accounts are coded and can be properly reported.
Forward the completed template to DDA Saving EForms via Microsoft Outlook email.
Clerk of Court Certificate of Deposit (CD) Accounts
Complete the CD Clerk of Court EForm for all new accounts. This is necessary to ensure that the
accounts are coded and can be properly reported.
Forward the completed template to CD IRA E-Forms via Microsoft Outlook email.
COLLATERAL RESERVE ACCOUNTS
Refer to Deposit Account Policy to view the Policy.
Refer to Collateral Reserve Accounts Standards to view the Standards.
Refer to the Collateral Reserve Accounts Quick Reference Guide for more on Collateral Reserve
accounts. This document is a good overview of key information about the Collateral Reserve Account.
A Collateral Reserve Account (type 121) is a “special use” depository account related to repayment of
BB&T’s Asset Based Lending (ABL) business. Clients with Collateral Reserve Accounts incur fees for
depository and treasury services that are a part of his/her ABL lending/credit line activities. At account
opening, a type (121) account is automatically blocked to debits by a "D" Block in the Deposit System.
Clients are prohibited from debit access to their Collateral Reserve Account, including online, ATM and
debit card transactions.
Once instructed by the Relationship Manager (RM) managing the ABL credit relationship to open a
Collateral Reserve Account, associates with Client Central Access should do the following:
1. Open a new (type 121) account.
2. If desired, order deposit tickets, stamp, etc. for the Collateral Reserve account; do not order checks
for a Collateral Reserve Account. In the comments section, of the order setup, write: “debit charges
from the client’s operating account number (list account number here)”.
3. Submit Account Analysis maintenance to group the Collateral Reserve Account to the client’s
operating account to ensure that treasury and deposit fees are charged to the operating account.
4. If desired, setup the client to receive only inquiry access to the Collateral Reserve Account in Small
Business Online Banking or CashManager Online, whichever the client uses for his/her operating
account.

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DEPOSIT ACCOUNT CONTROL AGREEMENT (DACA)
Contact the RBOM, AOO BTL or AOO HTL prior to discussing and processing DACA account requests
with the client.
Refer to Control Agreements on Deposit Accounts Policy to view the Policy.
Refer to Control Agreements on Deposit Accounts Standards to view the Standards. Step-by-Step
instructions for processing control agreements and a definition is available via the Policy and
Standards.
DOING BUSINESS AS (DBA) ACCOUNTS
Refer to Business Deposit Account Opening Standards and CIF/Account Titles Standards to view the
Standards.
An assumed name is a name under which an individual or a corporation may conduct business that
differs from the legal name. A corporation can use multiple assumed names.
NOTE: Branch associates must take appropriate steps to ensure that the person is who
he/she claims to be and that they have the authority to sign or conduct transactions on
behalf of the business under the assumed name.
A list of identification documentation options that should enable a branch associate to verify if a client is
qualified to open a DBA account is located under Procedure in Section I.
For assistance with determining whether a client qualifies for a DBA account, contact Branch Information
at 877-752-5544.
Specific rules for DBA's are located in the CIF/Account Titles Standards.
NOTE: Clubs should have only the club’s name with their Tax Identification Number (TIN)
entered on CIF. Do not use the Social Security Number (SSN) of a signer on the
account on AIF or CIF. If requested, the signer’s name may be entered on the alternate
address.
Clients may designate a special usage for club accounts with an account description
preceding ACCT or FUND. This information should be entered on the next available
line of the account title on AIF after the club’s name has been listed. Only the club’s
name should be entered on the CIF record using the TIN assigned to it and related as
Primary (PRI). The CIF and AIF records should read as follows:
CIF Quail Ridge Hunting Club REL PRI (Business CIF with TIN)
AIF Quail Ridge Hunting Club
Christmas Banquet Fund

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ESCROW (AGENT) ACCOUNT
Refer to Escrow Accounts Standards to view the Standards.
An agency (e.g., an escrow agent), an attorney-in-fact, or an attorney holding funds for a client,
relationship exists when an individual or entity is authorized to act on behalf of another person or entity
(e.g., renter’s deposit account, builder’s deposit account, etc.).
Branch associates will establish the account then complete the BB&T Escrow Agent Certification; which
prefills from Client Central at account opening.
Refer to BOM section E-650 - Escrow Accounts to view additional procedures when establishing Escrow
Accounts.
Refer to Forms and Examples section E-650 - Escrow Accounts to view sample BB&T Escrow Agent
Certification.
FOREIGN/INTERNATIONAL ACCOUNTS
Banks:
The International Services Division has direct responsibility for all foreign correspondent bank
relationships. Only the International Services Division may open deposit accounts for foreign banks. The
International Services Division will prepare appropriate due diligence, relationship servicing, monitoring,
compliance and necessary regulatory certifications.
Commercial (Business):
The International Services Division, occasionally, will have referrals of companies who wish to open a
depository banking relationship with BB&T. Usually these referrals are from foreign correspondent banks
and established calling contacts. The International Services Division will introduce these clients to the
branch location desired by the prospective client. In these cases, the International Services Division will
secure a recommendation from the foreign bank and assist in having the account opening documentation
completed.
For all foreign businesses, even those not referred by International, there are specific documentation
requirements. Documentation is necessary to assist in identifying the owner(s) of the business and the
validity of the business. Provide BSA’s EDD Management Group via fax (252) 293-9027 or via internal
mail, M/C 100-01-05-60 a copy of the following documentation:
 Primary Identifying Documentation:
 Client’s Articles of Incorporation
 Corporate Resolution,
 Partnership Agreement,
 Business Prospectus and/or Offering Memorandum, (if applicable)
 Allocation of business shares if available (Registered Bonds or Bearer Shares),
 Any other documentation provided by the client during account opening.

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NOTE: It is not necessary to obtain BSA’s EDD Management Group approval to establish a
foreign/international business account.
Refer to Section VII category of this BOM section for documentation procedures for completion of the
Authorization Agreement for Deposit Account, which will pre-fill in Client Central when establishing an
international business account.
GIRL SCOUTS/BOY SCOUTS/CLUBS/TROOPS
Refer to BOM section C-375 – CIF/Account Titles to view procedures.
HEALTH INSURANCE PORTABILITY ACCOUNTABILITY ACT (HIPAA)/HEALTH INFORMATION
TECHNOLOGY FOR ECONOMIC AND CLINICAL HEALTH ACT (HITECHA)
HIPAA/HITECHA facilitates the exchange and payment of health care providers. Most areas of the Bank
will not be affected except for Business Loan Administration and Treasury Services (Lockbox). Branch
associates should not sign a Business Associate Agreement provided by the client.
When Protected Health Information is involved, the Account Officer should have the client sign BB&T’s
Business Associate Agreement. The Agreement should be forwarded to Heather Morton, Business Loan
Administration, Winston-Salem, NC at MC 001-16-06-30 for signing on behalf of the Bank.
If not a commercial loan relationship, forward contract to Patricia (Patty) Binns, Treasury Services,
Charlotte, NC at M/C 500-96-01-99.
Should a client not wish to sign the BB&T Model Business Associate Agreement, the Account Officer
should contact Lori Beck at (336)-733-2070, Robert Wirth at (919) 745-5135 or Lisa McDougald at (919)-
745-5065 of the BB&T Legal Department. Under no circumstance should the Account Officer sign the
business associate agreement presented by our client without in-house counsel’s prior approval.
Business associate agreements impose restrictions and obligations on BB&T concerning the privacy and
security of protected health information. The agreements proposed by our clients may be overly
broad and may contain provisions that are not required by HIPAA/HITECHA.
Refer to the BB&T Legal Training Reference Materials and Forms to view additional HIPAA/HITECHA
procedures.
LIMITED LIABILITY COMPANY (LLC) ARTICLES OF ORGANIZATION
A date of dissolution may be stated in each LLC Articles of Organization. Branch associates are required
to review the Articles of Organization to ensure the "Date of Dissolution" for the LLC has not passed
before opening the newly requested account. BB&T is not responsible for "monitoring" the date after the
account is established. The responsibility of “monitoring” the “Date of Dissolution” is the duty of the
Members of the LLC.

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PUBLIC FUND ACCOUNTS
State statutes require that BB&T collateralize public fund deposits in excess of Federal Deposit Insurance
Commission (FDIC) limits. Refer to BOM section P-625 - Public Fund Accounts to view additional
procedures.
TRUST ACCOUNTS
A trust account is an account opened by one (1) person (the Trustee) for the benefit of another (the
beneficiary). The branch associate should have the trustee complete the BB&T Trust Certification.
Branch associates in Tennessee must have the trustee complete the BB&T Trust Certification -
Tennessee.
Refer to Forms and Examples section A-129B to view a sample and completion instructions.
The Trust Accounts Reference Guide provides additional aid for establishing trust accounts.
Section VI – Resolution and Agreement for Deposit Account
Complete the Resolution and Agreement for Deposit Account form in Client Central for each new
business client (Corporation, Partnership, Unincorporated Association, Limited Partnership, and Sole
Proprietorship). This document outlines the authority of individuals to act for these entities to open
depository accounts as indicated below:
A Designated Representative (DR) is authorized to act on behalf of the company; and Authorized Signer
(AS), (unless also a DR) is simply the person authorized to conduct transactions on the account – but is
not necessarily authorized to sign contracts.
A DR not on a signature card
Can:
 obtain account information,
 open accounts,
 close accounts,
 add or delete signers, and
 execute contracts for: safe deposit boxes, treasury services, debit cards, credit cards, on-line
banking.
Cannot:
 wire funds,
 make debit withdrawals,

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 transfer funds through any channel, and
 sign counter-checks.
A DR on a signature card and Authorized Signer on the account
Can:
 do everything listed above in both categories
An Authorized Signer on the account but not on the Resolution
Can:
 conduct all transactions on the account
Cannot:
 open accounts;
 execute contracts for safe deposit boxes, treasury services, debit cards, credit cards, On-Line
banking
Resolutions should be sent to Centralized Document Scanning, Wilson, NC, at M/C 100-99-15-11 daily to
be imaged. Place the resolution in a plastic bag; do not fold/crease or place resolutions in
interoffice envelopes.
Refer to Forms and Examples section A-129B to view a sample and completion instructions for the
Resolution and Agreement for Deposit Account.
Section VII – Authorization Agreement for Deposit Account (applicable to
foreign/international business accounts only)
Complete the Authorization Agreement For Deposit Account form in Client Central for each new
international client relationship established. This document outlines the authority of individuals to act for
these international entities to open depository accounts, sign checks, use facsimile signatures, execute
night deposit agreements, open safe deposit boxes, appoint signers on accounts and execute wire
transfers.
Authorizations should be sent to Centralized Document Scanning, Wilson, NC, at M/C 100-99-15-11 daily
to be imaged. Place the authorization in a plastic bag; do not fold/crease or place resolutions in
interoffice envelopes.
Refer to Forms and Examples section A-129B to view a sample and completion instruction for the
Authorization Agreement for Deposit Account.
Section VIII - Signature Card SmartScan/Print Documents
In the final steps of the account opening process, the signature card will pre-fill, and display as a document
eligible for scanning for each new account opened (checking, savings and certificates of deposit).
Refer to the SmartScan for Signature Cards to view additional Client Central procedures.

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NOTE: For business/commercial accounts, the first signature line should be the person
signing on behalf of the business/entity. The person signing on behalf of the
business/entity is not required to sign the signature card a second time; his/her
signature represents “an authorized signer” on the account. All other signers are
signing as ‘authorized signers’ on the account.
NOTE: For Business Accounts opened online, refer to BOM section O-525 - Online Banking
for instructions on opening Business Online accounts.
Signature Card Addendum
The Signature Card Addendum is a form, which allows for more signers than the signature card will
accommodate. Complete as applicable to the number of signers requested by the client. (Client does not
need to sign the Signature Card Addendum if he/she signed the Signature Card).
The signature card addendum will print with the signature card, if applicable. Once the Signature Card
Addendum is selected, click ‘Next’ to proceed with scanning.
Refer to the SmartScan for Signature Cards to view additional Client Central procedures.
NOTE: Refer to Forms and Examples section A-129B to view a sample signature card
addendum. Should associates have difficulty completing the signature card, contact
Branch Information at 877-752-5544.
Section IX - Supply Requirements
To open a business account, the following supplies are needed:
 Pre-encoded starter kit;
 Signature Card, which is via the Client Central application,
 Resolution and Agreement for Deposit Accounts, which is via the Client Central application;
 Authorization Agreement For Deposit Accounts, which is via the Client Central application and
applicable for foreign/international clients only;
 Commercial Bank Services Agreement, which is via the Client Central application;
 ATM/Everyday Debit Card Overdraft Decision Notice, which is via the Client Central application;
 Business Services Pricing Guide, which is via the Client Central application;
 Brochure - Shedding Some Light On Night Deposits C0014040003 (when applicable);
 Interest Schedule (if applicable to the account type, which is via the Client Central application);
 Commercial Deposit Preparation Guidelines are available via the Client Central application; and
 Associate’s BB&T Business/Calling Card.
NOTE: Supply requirements must be presented to potential clients when opening accounts
away from the branch; refer to OFFSITE CLIENT CONTACT category in this section to
view procedures.

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Section X - Account Opening-Procedures
THE SIX STEP ACCOUNT OPENING/BUSINESS
Refer to the 6 Step Account Opening Quick Reference Guide as a tool to ensure all account-opening
steps are completed properly.
NOTE: It is critical that associates provide the Business Services Pricing Guide and
Commercial Bank Services Agreement to the client PRIOR to opening a checking or
savings account.
CLASS CODES
Refer to the Account Class Guide to view documentation.
BUSINESS CLASSIFICATION AND INDUSTRY CODE
The Business Classification represents specialized business industries of interest to BB&T. The Business
Classification is a required field and must be completed in the Client Central application to continue with
account opening. In addition to Business Classification, a selection must be made for the Industry Code
which is in the same area of the Client Central application as the Business Classification.
Branch associates must enter the Business Classification and Industry Code for all new or existing
business clients when a new account is opened, a new loan is originated, or when a new or existing
business client is being added to an existing Deposit account. The Business Classification and Industry
Code are required to recognize businesses that may be considered high risk.
Select the required Business Classification in the Business Client Profile; the list of classifications is
indicated in the drop down box. Below the Business Classification, select the Industry Code. The list of
available Industry Codes is indicated in the associated drop down box(es). In all cases, select the option
from each list that best describes the type of business for the business client. To view instructions, refer
to the Business Classification and Industry Codes via the Online Resource Manual. To view the Business
Classification and Industry Codes refer to the Industry Code Report.
Once the Business Classification and Industry Code are established by the branch associate, the
classification may not be changed. If the Business Classification or Industry Code needs to be modified,
the branch associate must send an email to EDDInquiries@bbandt.com. The email must contain the
following three (3) pieces of information:
1. Business Name;
2. Tax Identification Number (TIN); and
3. Business type/description.

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BUSINESS RECOVERY
Accounts are to be keyed on Client Central on the same day the deposit is scanned. If an account cannot
be keyed immediately due to PC or system problems, the account must be keyed as soon as the
problems are resolved. Use a New Business Account Information Sheet to record information that may
be needed when keying the account at a later time.
LIST CHECKING (CLIENT CENTRAL “BANKING ELIGIBILITY” ERROR MESSAGE)
When a new account is being opened, or a client is being added to an existing account, the client is
subject to a review for banking eligibility. Account opening/ownership maintenance may proceed once it
has been determined that the client is eligible to bank at BB&T. Eligibility is determined systematically;
should the “Banking Eligibility” error message appear when the account is keyed, contact BSA/AML,
Wilson, NC at 877-300-5785.
CLIENT CENTRAL QUESTIONS AND ANSWERS PAGE
When a new account is being opened, or a client is being added to an existing account, the client is
reviewed to determine if BB&T requires additional information about the client. If more information is
needed, a page with questions for the client will be presented to the branch associate via Client Central.
The questions must be answered in order to proceed with the account opening/ownership maintenance.
In addition, BSA/AML may question the branch associate after the Client Central input. It is important to
refer to the ML, BBTL, AOO, AOO Consultant, AOO Compliance or AOO BTL for assistance in
addressing the questions.
CIF/AIF STANDARDS
Refer to CIF/Account Titles Standards to view the Standards.
Refer to BOM section C-375 - CIF/Account Titles to view procedures to be used for input on the CIF/AIF
when registering business clients.
BB&T PHONE24®
Discuss and explain with the client the features of BB&T Phone24®. Explain pricing and how the client
has the option of obtaining account information through BB&T Phone24® or speaking with a
representative of BB&T Phone24® for additional assistance. Call BB&T Phone24®: 800-226-5228.
Select the appropriate “Menu” option for a demonstration of BB&T Phone24®.
Clients not having an electronic access device (i.e., BB&T Business Check Card or ATM card) can be
given immediate access to BB&T Phone24®. Branch associates can request a client security code via an
AR61 screen. Refer to BOM section P-607 - Phone24 (BB&T Phone 24®) to view tier access for
business clients and additional BB&T Phone24® procedures.

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BB&T SMALL BUSINESS CLIENTS
Discuss and explain with this segment of clients the features of BB&T Phone24®. Explain pricing and
how the client has the option of obtaining account information through BB&T Phone24® or speaking with
a representative of BB&T Phone24® for additional assistance. Call BB&T Phone24® at 800-Bank BBT
(800-226-5228). Select the appropriate “Menu” option to speak with a BB&T Client Service Associate.
INITIAL DEPOSIT
Place a Reg CC hold on the initial deposit as appropriate; refer to BOM section R-815 - Reg CC
(Holds/Funds Availability) to view additional procedures.
NOTE: If an account is opened and no deposit made; the account will be automatically closed
after sixty-two (62) calendar days.
CHECKING/SAVINGS STATEMENT
Review the sample bank statement with the client. Explain how to reconcile the statement and how the
statement is cycled.
TELECOMMUNICATIONS DEVICES FOR THE DEAF (TDD) SERVICE
Branch associates may offer hearing impaired clients a special toll-free number, 888-TDD-4BBT
(888-833-4228) to obtain information about any of his/her bank accounts. The TDD Service requires the
client to have special equipment in order for BB&T to communicate with him/her. To set up the TDD
Service, refer to BOM section P-607 - Phone24 (BB&T Phone24®) to view set up instructions.
Section XI - Introduction of New Clients
All new account clients should be escorted to the teller line and other applicable front line branch
associates for formal introduction. Use “The Perfect Client Experience” and follow the guidelines as
outlined in the Integrated Relationship Management philosophy.
Section XII – Revised Resolution And Agreement For Deposit Account, Authorization
Agreement For Deposit Account, Signature Card and Commercial Deposit Processing
Agreement (Night Depository)
ADDITIONS/DELETIONS OF CERTIFYING OFFICERS/DESIGNATED INDIVIDUAL SIGNERS
A new Resolution and Agreement for Deposit Account or Authorization Agreement for Deposit Account
(applicable to foreign/international accounts) is needed only when there is a change in the Designated
Individual on the current Resolution.
A new Resolution and Agreement for Deposit Account/Authorization Agreement For Deposit Account is
needed should the client notify the bank of a change in Certifying Officer(s) on the current Resolution and
Agreement for Deposit Account Authorization Agreement For Deposit Account.

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To view a copy of a Resolution and Agreement for Deposit Account/Authorization Agreement for Deposit
Account, access the Client Central application and proceed as outlined below:
 Choose the “Select Client” function;
 Enter the applicable search criteria;
 Select the “Business Resolutions” tab; and
 Select the “View Existing Resolutions” link.
For TINs that have more than two hundred and fifty (250) Resolutions, contact Centralized Document
Scanning in Wilson, NC, at (252) 246-3164. The following information is needed:
 Business name;
 Account Number; and
 Tax Identification Number (TIN).
NOTE: Tax Identification Number is not applicable when requesting to view a copy of the
Authorization Agreement For Deposit Account. Select the link “View Existing
Resolutions” to request the copy.
Images or copies of Resolution and Agreement for Deposit Account and Authorization Agreement for
Deposit Account (for International accounts) and signature cards should not be printed, unless it is
absolutely necessary. If images or copies are printed, they are to be treated as internal, confidential
documents and should not be given to clients.
Refer to BOM section C-397 - Confidential Trash/Information Disposal to view additional procedures
regarding internal, confidential documents.
ADDITIONAL ASSISTANCE
Contact Branch Information at 877-752-5544 for additional assistance.

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