|Our HSA custodian, National Advisors Trust South Dakota (NATSD), provides oversight to the Health Savings Account (HSA) activity managed through our platform. From time to time, NATSD requires updates to our compliance program, and our HSA operations department will be implementing a change in identification verification as of December 1, 2020.
This change will further improve our compliance in a manner that actually reduces your own administrative burdens. Although this affects account approval and opening, it does not impact the application or enrollment process – which means there is nothing you need to do on your end to accommodate or prepare for it.
New Process for Identification/OFAC Failures
Our business model is to support the TPA, while they support their clients. Thus, our current process for handling Identification or OFAC failures is to ask the TPA to request additional Identification from the applicant, such as a driver’s license or utility bill proving place of residence. However, in order to satisfy the requirements NATSD has placed on us, our operations department will send out the initial communication to the account owner and only involve the TPA if we cannot get a response.
Beginning December 1, 2020, any account failing the OFAC or ID verification (IDV) will automatically be placed in Pending status and we will send the applicant an email requesting additional documentation. The email notice will provide clear instructions on the type of documentation needed. In addition, the notice will have a link the applicant can use to upload the documentation via their smartphone. (To see an example, click below.)