Comerica Bank (CMA) and all of its subsidiaries, including Comerica Bank, comply with the Bank Secrecy Act (BSA) and USA PATRIOT Act requirements. In accordance with these requirements, Comerica Bank has designated a BSA/AML Compliance Officer, implemented policies, procedures, and controls designed to guard against money laundering; instituted an ongoing training program; and provided for independent auditing of the program. Comerica's Customer Identification Program (CIP) is a core element of the AML Program. Comerica's CIP as required by USA PATRIOT Act Section 326 and its regulations, requires that at a minimum we collect and verify the following identifying information from customers seeking to open new accounts: name, identification number, address, and date of birth as applicable. Additionally customer information is compared to government lists of known or suspected terrorists or terrorist organizations.