Introduction

When you onboard end-customers to our platform, they are checked within seconds and typically automatically approved by our system. In some cases, we may need additional documentation from the customer or to conduct a manual review ourselves. In those cases, Unit will investigate, manage, and quickly resolve the issue.

This guide explains how our end-customer onboarding process works, including details on:

• The information we require for individual and business end customer applications.
• Common reasons why applications may require manual review.
• Common reasons why submitted documentation may be rejected.

Information Collection

To comply with Bank Secrecy Act laws, you will be required to collect and pass certain information to Unit depending on the type of applicant (see our API documentation).

Key Terms

• Individuals are natural persons.
• Businesses are legal entities (but may include individuals who are onboarding as a legal entity, such as a sole proprietor or individual LLC).
• US Persons are individuals with a U.S. Taxpayer Identification Number (TIN) – typically a Social Security Number (SSN).
• Non-US Persons are individuals without a TIN.
• Beneficial Owners are any individuals that own 25% or more of a business.
• Officers are a single individual with responsibility to control manage or direct a business.

There are two types of onboarding applications: Individual and Business. The following are the minimum attributes that are required to be collected and verified for both businesses and individuals.

Applicant Type	Information Required	Notes
Individual	Legal name; Date of Birth; Physical Address; Government Identification Number: For US Persons: Taxpayer Identification Number (TIN) or Social Security Number (SSN) For Non-US Persons: Passport number (and country of issuance, date of issuance, and expiration date);	Copy of Passport and Address Verification is required for all Non-US Persons. Physical Address must be a US address.
Business	Legal Entity Name; Taxpayer Identification Number; Physical Address; Information listed for natural persons for each Beneficial Owner and Officer of the legal entity	Companies that are publicly traded in a major US stock exchange are subject to lighter onboarding requirements. If your customer base includes publicly traded companies, please reach out to Unit for additional information. Physical Address of the business must be a US address.

Customer Notification

All Accounts

You must provide your customers with adequate notice that Unit is requesting information to verify their identity. The notice must describe the identification requirements and be provided in a manner that allows a customer to view it before opening their account. The following is a sample notice language:

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT — To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

Customer’s personal information will be protected. Banks and their partners are held to federally regulated standards of protecting customer information. For security reasons, we can't give specifics, but we employ a variety of tools such as encryption, one-time passwords, access controls, and employee background checks to protect customer information.

Business Accounts

In addition to providing a notice that meets the requirements described above, business account notices also must include a beneficial ownership attestation. (Beneficial owners are individuals or businesses that own 25% or more of the business.)

The following beneficial ownership attestation must be shown on the information collection screen:

By providing the information above, I hereby certify, to the best of my knowledge, that the information provided above is complete and correct.

Information Verification

Unit will pass the collected information to our vendor, which will verify the information provided and look for any fraud indicators. At times, a manual review may be necessary.

Manual Reviews

Our goal is to have a completely non-documentary process that enhances the customer experience for both individuals and businesses. However, if a manual review is required, we will perform the review based on when the status of the application turns to “Pending Review”:

Pending Review Status	SLA
Between 8:00am - 8:00pm EST	Manual review completed within two (2) hours of receipt
Between 8:00pm - 8:00am EST	Manual reviews completed by 9:00am EST the following day

Individual Review

Individual applications may be flagged for manual review for multiple reasons. The table below outlines these reasons and indicates why such applications may be approved or denied.

• Note: This table is for informational purposes only – Unit will provide this information via API, including the message sent to the end customer. Consult the API documentation for further details.
• Note: Please see our technical documents for the requirements to implement Iovation. There are additional steps to enable device verifications.

Check	Description	Providers	Outcome	API message	Message to end customer
ID Theft high risk	ID theft risk score is above threshold	Sentilink	Deny	Denied	We are unable to verify your identity at this time. Please contact our customer service with questions.
Address Warning	Matches the list of prison addresses Is associated with suspected or confirmed fraud	Socure	Manual Review	Address Verification Required	Please provide a document to verify your address. Document may be a utility bill, bank statement, lease agreement or current pay stub.
Address Not Verified	Address provided is in a different state than the address detected by vendor
PO Box	Address matches the list of PO Boxes or private Mailbox facilities
SSN Warning	Unusual number of SSNs associated with this identity (name, address and phone number) SSN associated with confirmed fraud	Socure	Manual Review	SSN Verification Required	Please provide a document verifying your Social Security Number (SSN) such as a filed tax return, W-2 or social security card.
Deceased SSN	SSN reported as deceased
SSN Miskey	Individual’s SSN appears to have been miskeyed
SSN Not Verified	SSN provided does not match SSN found by vendor
DOB Not Verified	Year of birth does not match DOB not located	Socure	Manual Review	ID Document Required	Please provide a copy of your unexpired government issued photo ID which would include Drivers License, State ID or Passport.
DOB Miskey	Individual’s DOB appears to have been miskeyed
Minor under 18	Individual’s DOB lists the applicant as a minor under the age of 18
Name Not Verified	Last name does not match last name located by vendor
Fraud Score Risk	Medium-high Socure Sigma Fraud Score
Adverse Media Issue	Individual is associated with any type of adverse media, including: Financial Crime Fraud Narcotics Sexual Crime Terrorism Violent Crime	Socure	Manual Review	Manual Review (required documents will be determined by Unit upon manual review)	We’re having trouble verifying your identity. If your application was processed between 8 am to 8 pm EST, please allow 2 hours for someone to review your application. If your application was received between 8 pm EST to 8 AM EST, we will review your application by 9 AM EST the following day. We will contact you if any additional documentation is needed.
OFAC Issue	Individual matches OFAC Consolidated List or OFAC SDN List
Domestic PEP Issue	Individual matches any of the domestic Politically Exposed Persons (PEP) lists
International PEP Issue	Individual matches any of the International Politically Exposed Persons (PEP) lists
Foreign Device Warning	Detects if the device has an IP address outside of the U.S.	Iovation	Manual Review	ID Document Required	Please provide a copy of your unexpired government issued photo ID which would include Drivers License, State ID or Passport.
Device Warning	Detects if a device has been used for previous application(s) or device risk score is determined to be high risk (ex. Uses a mobile emulator).
Device Warning OR Foreign Device + Fraud Risk	If the “Device Warning” or “Foreign Device” flag is triggered as well as the “Fraud Risk” flag	Socure, Iovation	Deny	Deny	We are unable to verify your identity at this time. Please contact our customer service with questions.
Fraud Score Warning	High Socure Sigma Fraud Score	Socure
Denylist Denied	Information on the application is a match to information on Unit’s internal deny list. Could be a match to a name/date of birth combination, SSN match or address match depending on the reason the individual is on the denylist.	N/A
Approved	Application Approved	Socure, Vouched, Iovation	Approved	Approve	Congrats - your application has been approved!

Business Review

Business applications may be flagged for manual review for multiple reasons. The table below outlines these reasons and indicates why such applications may be approved or denied.

• Note: This table is for informational purposes only – Unit will provide this information via API, including the message sent to the end customer. Consult the API documentation for further details.
• Note: If a business is approved but an individual associated with the business (Officer or Beneficial Owner) is stopped for manual review or denied, the application will not be auto approved. If an Officer or Beneficial Owner is denied then the application will go to manual review and will be denied.

Check	Description	Providers	Outcome	API message	Message to end customer
FEIN not found/verified	Business name could not be associated with the FEIN in Middesk real-time IRS check	Middesk	Manual Review	FEIN Document Required	Please provide a document verifying your Federal EIN such as a filed business tax return, IRS 147c letter or the IRS Form CP 575.
Company name not verified	Business name could not be found in Middesk real-time state registration database check	Middesk	Manual Review	COI Document Required	For Corporation: Please provide a certified copy of the Articles of Incorporation or Certificate of Incorporation. For Partnership: Please provide a copy of the Partnership Agreement. For LLC: Please provide a certified copy of the Articles of Organization.
State Registration Mismatch	The business isn’t registered with the Secretary of State	Middesk
Secretary of State Warning	Review flags detected with Secretary of State
True Industry Warning *Only if Website is provided with application (optional field)	The business’s true industry is associated with high risk. Examples: Adult Cannabis Virtual Currency Gambling	Middesk	Manual Review	Manual Review (required documents will be determined by Unit upon manual review)	We’re having trouble verifying your business information. If your application was processed between 8 am to 8 pm EST please allow 2 hours for someone to review your application. If your application was received between 8 pm EST to 8 AM EST, we will review your application by 9 AM EST the following day. We will contact you if any additional documentation is needed.
OFAC Issue	Business matches OFAC Consolidated List or OFAC SDN List
Pending	Async with Middesk, systems need 24 hours to synchronize	Middesk	Pending	Pending	Thank you! Your application is currently under review. It will take a few minutes, so you may stay on this page, but we will get back to you via email in any case.
Approved	Application Approved	Middesk	Approved	Approve	Congrats - your application has been approved!
Flags associated with each Officer/ Beneficial Owner	Apply the full individual CIP to officer and all beneficial owners and check for any of the results under individual CIP *If the individual associated with the business is denied then the business application will be denied	See individual section	See individual section

Decision Overrides

Applications that are denied or require further documentation for any reason other than a validation reason can be overridden upon client request if the client chooses to accept the risk of opening the account. Examples of situations where an override can be requested without additional documentation include:

• Fraud Risk
• Denied Fraud
• Address Warning
• Device Warning

Approved Document Types:

Below is a list of approved document types for both individual and consumer applications. Exceptions may be made on a case by case basis using a risk based approach.

Business or Individual	Verification Type	Approved Document Types	Notes
Individual	Identity Verification	Driver's License State ID Passport/Passport Card Tribal Identification Card Alien Identification Card Permanent Resident Card/Green Card US Visa Card State issued Driver’s Permit Mexican Matricula Consular Card Mexican Voter ID School ID (minors only) Work ID (minors only)	Must include an unexpired government issued photo ID *Work ID and Student ID are only acceptable document types when KYC is being performed on someone under the age of 18 at the time of application *Other foreign photo IDs may be approved as needed and will be added to the list and requested for approval if they become common ID types or a program is onboarded with a specific need. *If an ID is required solely to verify Date of Birth, a birth certificate may also be accepted. * Front and back images of all ID documents except passports are required.
Individual/Business	Address Verification	Utility Bill Bank Statement Lease Agreement Pay Stub Insurance Bill/Statement Driver’s License (unexpired) Incorporation Documents (for businesses) EIN Letter (For businesses)	Any document used to verify address must be current within the last six months in order to be considered valid *Utility Bills, Bank Statements or Pay Stubs must be current within the last six months. Lease agreement must still be valid (ex. 12 month lease dated 10 months ago)
Individual	SSN Verification	Filed Tax Return W-2 Social Security Card 1099	Tax return or W-2 must be current within the past two filing years The same documents are acceptable for verifying ITIN as well.
Business	EIN Verification	EIN Letter from the IRS Filed Tax Return	Tax return must be current within the past two filing years
Business	Business Verification	Certificate of Incorporations Articles of Incorporation Partnership Agreement Articles of Organization Corporate Resolutions LLC Operating Agreement Certificate of Assumed Name Certificate of Formation Trust Agreement Organization Documents	Business verification documents vary depending on the business type. This list includes the most common forms of verification; however, there may be others that are considered as well. *If a business is international, proof of organization/incorporation internationally will be required and reviewed with a risk based approach.

Evaluation Flags

All evaluation flags will be displayed in the Client dashboard in the Application page. The flags are color coordinated:

• Green: good
• Red, orange or yellow: Application was stopped for manual review or document upload
• Blue/Grey: Documents required or informational only (does not impact decisioning)

For businesses, evaluation flags will be displayed for the business, the officer and each beneficial owner.

Document Rejection Reasons

The following table outlines reasons a document may be denied through the automatic document verification tool, Vouched.

• Note: This table is for informational purposes only – Unit will provide this information via API, including the message sent to the end customer. Consult the API documentation for further details.

Reject Reason	Description	Reason Code	Message to End User
Poor Image Quality	The image is unable to be read Blurry image Glare/light blocking the image	PoorQuality	The image provided was unable to be verified due to a poor image quality. Please resubmit the image and be sure all personal information is legible.
Name Mismatch	First name doesn’t match Last name doesn’t match	NameMismatch	The name on your ID does not match the name on the application. Please resubmit your ID and be sure all personal information is legible.
Address Mismatch	Address does not match address on the application	AddressMismatch	The address on the document provided does not match the address on the application. Please resubmit an address verification document with the same address provided on the application.
SSN Mismatch	The Social Security Number does not match the SSN on the application	SSNMismatch	The SSN on the Social Security Card provided does not match the SSN on the application. Please confirm the SSN has been entered into the application properly or resubmit a copy of your Social Security Card ensuring the number is legible.
Date of Birth Issue	The DOB on the ID does not match the DOB on the application	DOBMismatch	The Date of Birth on the uploaded ID does not match the Date of Birth on the application. Please verify the information on the application is correct or resubmit a document verifying your Date of Birth.
Expired ID	The ID provided is expired	ExpiredId	The ID you provided is expired. Please provide a current ID for verification such as Driver’s License, Passport or State ID.
EIN Mismatch	The EIN on the document provided does not match the EIN on the application	EINMismatch	The EIN on the document you provided does not match the EIN on the application. Please make sure the information provided on the application is correct and submit documentation verifying the EIN.
State of Incorporation Mismatch	The state of incorporation does not match the state of incorporation provided on the application	StateMismatch	The state of incorporation does not match the state of incorporation provided on the application. Please make sure the information provided on the application is correct and submit documentation from the state in which the business is incorporated.
Other	Any reason not listed above such as: Document appears fraudulent/counterfeit Document type not accepted	Other	Free text field entered by Unit