Safety & Soundness

Financial institutions can rest assured that Primary Financial is a safe and sound organization.

• We are owned by the nation’s corporate credit unions. National publications have written numerous articles touting the cooperation of the corporate credit union network regarding their ownership of Primary Financial.
• As a credit union service organization (CUSO), we regularly provide the National Credit Union Administration (NCUA) access to our books and records. In addition, we are audited annually by an independent accounting firm and enlist a third-party auditor to conduct procedures over the safekeeping function we perform. This safekeeping examination is conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. For a copy of the report, click here. Adherence to these standards is widely recognized as an indicator that a service organization has been subjected to an in-depth examination of its control activities by an independent, external accounting firm.
• CU Investment Solutions LLC (ISI) has an Office of Supervisory Jurisdiction within our office at 6640 Riverside Drive, Suite 430, Dublin, Ohio 43017. ISI is a member of FINRA and SIPC. ISI's home office is located at 8500 W 110th St, Ste 650, Overland Park, KS 66210.
• Primary Financial provides investors with free access to Veribanc ratings on each issuer in the SimpliCD program. For more information about Veribanc, click here.
• Each investor is the beneficial owner of all underlying certificates purchased. Early redemption of certificates is handled through the issuer of the certificate, with the investor incurring any and all resulting penalties.
• Primary Financial provides statements detailing daily placements and maturities as well as a monthly statement detailing each investor’s holdings.
• Primary Financial, as a safekeeping agent, requires participating issuers to title all CDs to reflect Primary Financial as the custodian, acting on behalf of the investor as owner. This method has been proven acceptable to the FDIC. Letters from the FDIC and the NCUA verifying the availability of deposit insurance for investors in the SimpliCD program are available upon request.
• Primary Financial requires a signed custodial agreement before any transaction takes place. It explains various rights and duties of Primary Financial as custodian. One of the requirements in this agreement is for Primary Financial to exercise ordinary care in the safekeeping and administration of investments for the investor.

USA PATRIOT Act

The USA PATRIOT Act (the “Patriot Act”) contains measures to prevent, detect, and prosecute terrorism and international money laundering. The following statement has been drafted in response to the provisions of the Patriot Act that require financial institutions to confirm their “correspondent accounts” are not with “shell banks” as defined by Section 313.

Primary Financial is a U.S.-domiciled corporation with a physical addresses at 6640 Riverside Drive, Suite 430, Dublin, OH 43017. Primary Financial is engaged in matching investors in, and issuers of, certificates of deposit issued by depository institutions that are federally insured by the Federal Deposit Insurance Corporation or the National Credit Union Share Insurance Fund. Primary Financial’s Ohio office has been designated an Office of Supervisory Jurisdiction of CU Investment Solutions, LLC. ("ISI"), a member of the Financial Industry Regulatory Authority ("FINRA").

Primary Financial is organized as a credit union service organization and is owned by 10 corporate credit unions. Primary Financial maintains operating records related to its activities and, as a credit union service organization, is subject to periodic review by the National Credit Union Administration ("NCUA"). The NCUA is an independent federal agency that supervises and insures credit unions nationally. The customers of Primary Financial, for the most part, are U.S.-domiciled credit unions. Primary Financial is a credit union service organization and does not, as a result of its normal business activities, maintain relationships with individual persons as defined by the USA PATRIOT ACT (the "Patriot Act"), Section 312.

Primary Financial is not subject to Customer Identification Program ("CIP") requirements as described in Section 326 of the Patriot Act. The CIP regulations are promulgated at 31 C.F.R. §§ 103.121-103.123. Because Primary Financial is neither 1) a bank, savings association, or credit union; 2) a broker-dealer registered or required to be registered with the Securities Exchange Commission; nor 3) a futures commission merchant or introducing broker, it is not subject to any CIP regulation. Primary Financial’s co-agents are corporate credit unions and as such, are subject to Section 326 of the Patriot Act. Accordingly, these corporate credit unions perform CIP procedures on their credit union customers as required, pursuant to 31 C.F.R. § 103.121.

Primary Financial has reviewed its correspondent relationships and can assure its customers and other business partners that it does not maintain account relationships with any "shell banks" as defined in Section 313 of the Patriot Act and furthermore, Primary Financial does not provide services to foreign banks. Primary Financial is not subject to the financial institution reporting and recordkeeping statutes and regulations promulgated under the Bank Secrecy Act and the Patriot Act because it is not a financial institution as defined in these provisions.