If your NDIP sub is a member of the NASD or is SEC registered, then there are requirements for USA Patriot Act Compliance. I'm not involved in a daily basis with our brokerage sub, but I do know that the NASD has issued a number of different pieces. As I recall the brokerage industry will be required to start filing SARs under BSA (Don't ya just love acromyns)is later this year.
If your sub is NASD regulated, I suggest you review the Conduct Rules at www.nasdr.com
. If that doesn't help then please provide more info in a subsequent post.