The USA PATRTIOT ACT was passed immediately after the attacks on the United States by certain terrorist groups on 9-11-2001.

Section 326 of the Act specifically addresses the need for banks, including banker's banks by implication, to obtain identification and verification of accountholders.

Minimum requirements of the Act include (as we understand they would apply to respondent bank accounts):

• Verification of the existence and good standing of the financial institution seeking to open an account at BBW.
• Verification of the organization by comparing the information provided to BBW with lists of known or suspected terrorists or terrorist organizations.
• Maintaining account information for at least five (5) years after the account is closed.

Bankers' Bank of the West has implemented a Customer Identification Program (CIP) that we deem is appropriate to adequately comply with the requirements of the Act.

BBW maintains accounts only for financial institutions and bank holding companies. In light of this fact, it is assumed that entities requesting an account at BBW will understand and comply with the above requirements of the Act by completing fully all new account forms required to open or update an account.

The policies and procedures governing the CIP are included in the bank's USA PATRIOT ACT policy and have been approved by the Board of Directors of the bank.