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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; and
  • 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 TypeInformation RequiredNotes
Individual
  • Legal name;
  • Date of Birth;
  • Physical Address;
  • Government Identification Number:
    • For US Persons: Taxpayer Identification Number (TIN)
    • 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
Business
  • Legal Entity Name;
  • Taxpayer Identification Number;
  • Physical Address; and
  • Information listed for natural persons for each Beneficial Owner and Officer of the legal entity

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 StatusSLA
Between 8:00am - 8:00pm ESTManual review completed within two (2) hours of receipt
Between 8:00pm - 8:00am ESTManual 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.
CheckDescriptionProvidersOutcomeAPI messageMessage to end customer
Address Warning
  • Matches the list of prison addresses
  • Is associated with suspected or confirmed fraud
ID Analytics, Socure Manual Review Address Verification RequiredPlease provide a document to verify your address. Document may be a utility bill, bank statement, lease agreement or current pay stub.
Address Not VerifiedAddress provided is in a different state than the address detected by vendor
PO BoxAddress 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
ID Analytics, Socure Manual Review SSN Verification RequiredPlease provide a document verifying your Social Security Number (SSN) such as a filed tax return, W-2 or social security card.
Deceased SSNSSN reported as deceased
SSN MiskeyIndividual’s SSN appears to have been miskeyed
SSN Not VerifiedSSN provided does not match SSN found by vendor
DOB Not Verified
  • Year of birth does not match
  • DOB not located
ID Analytics, Socure Manual Review ID Document RequiredPlease provide a copy of your unexpired government issued photo ID which would include Drivers License, State ID or Passport.
DOB MiskeyIndividual’s DOB appears to have been miskeyed
Minor under 18Individual’s DOB lists the applicant as a minor under the age of 18
Name Not VerifiedLast name does not match last name located by vendor
Fraud Score RiskOne of the following:
  • ID Analytics ID Score is greater than or equal to 800
    OR
  • Socure Sigma Fraud Score is greater than or equal to 0.95
Adverse Media IssueIndividual 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 IssueIndividual matches OFAC Consolidated List or OFAC SDN List
Domestic PEP IssueIndividual matches any of the domestic Politically Exposed Persons (PEP) lists
International PEP IssueIndividual matches any of the International Politically Exposed Persons (PEP) lists
Foreign Device WarningDetects if the device has an IP address outside of the U.S.Iovation Manual Review ID Document RequiredPlease provide a copy of your unexpired government issued photo ID which would include Drivers License, State ID or Passport.
Device WarningDetects 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 RiskIf the “Device Warning” or “Foreign Device” flag is triggered as well as the “Fraud Risk” flagID Analytics, Socure, Iovation Deny DenyWe are unable to verify your identity at this time. Please contact our customer service with questions.
Fraud Score WarningBoth of the following:
  • ID Analytics ID Score is greater than or equal to 700;
    AND
  • Socure Sigma Fraud Score is greater than or equal to 0.90
ID Analytics, 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
ApprovedApplication ApprovedID Analytics, Socure, Vouched Approved ApproveCongrats - 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.
CheckDescriptionProvidersOutcomeAPI messageMessage to end customer
FEIN not found/verifiedBusiness name could not be associated with the FEIN in Middesk real-time IRS checkMiddesk Manual Review FEIN Document RequiredPlease 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 verifiedBusiness name could not be found in any of the following:
  • OpenCorporates database
  • Middesk real-time state registration database check
OpenCorporates, 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 MismatchThe business isn’t registered with the Secretary of StateMiddesk
Secretary of State WarningReview 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 IssueBusiness matches OFAC Consolidated List or OFAC SDN List
PendingAsync with Middesk, systems need 24 hours to synchronizeMiddesk Pending PendingThank 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.
ApprovedApplication ApprovedMiddesk, OpenCorporates Approved ApproveCongrats - 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 sectionSee 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 IndividualVerification TypeApproved Document TypesNotes
IndividualIdentity Verification
  • Driver's License
  • State ID
  • Passport/Passport Card
  • Military ID
  • 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/BusinessAddress 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)

IndividualSSN 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.

BusinessEIN Verification
  • EIN Letter from the IRS
  • Filed Tax Return
Tax return must be current within the past two filing years
BusinessBusiness 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.

Evaluation Flags

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 ReasonDescriptionReason CodeMessage to End User
Poor Image Quality
  • The image is unable to be read
  • Blurry image
  • Glare/light blocking the image
PoorQualityThe 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
NameMismatchThe 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 MismatchAddress does not match address on the applicationAddressMismatchThe 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 MismatchThe Social Security Number does not match the SSN on the applicationSSNMismatchThe 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 IssueThe DOB on the ID does not match the DOB on the applicationDOBMismatchThe 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 IDThe ID provided is expiredExpiredIdThe ID you provided is expired. Please provide a current ID for verification such as Driver’s License, Passport or State ID.
EIN MismatchThe EIN on the document provided does not match the EIN on the applicationEINMismatchThe 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 MismatchThe state of incorporation does not match the state of incorporation provided on the applicationStateMismatchThe 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.
OtherAny reason not listed above such as:
  • Document appears fraudulent/counterfeit
  • Document type not accepted
OtherFree text field entered by Unit