On March 5, 2010, the SEC issued a policy statement to provide guidance that clarifies and consolidates existing regulatory expectations for obtaining beneficial ownership information for certain accounts and customer relationships for anti-money laundering purposes. Specifically, the guidance states that financial institutions should establish and maintain customer due diligence procedures that are reasonably designed to identify and verify the identity of beneficial owners of an account, as appropriate, based on the institution’s evaluation of risk pertaining to an account. The guidance took effect on March 5, 2010.