We have a customer that has multiple franchises all under seperate name and EIN; however, he is on all accounts. He is requesting to have access to all 4 DDAs via one online banking signin. We have told him no because they are all 4 seperate entities/businesses and therefore can not be combined. The customer is pushing the fact that he is the president of all 4 companies and has authorization on all 4 accounts. We have confirmation from SCC that he is indeed a director/officer on all 4 businesses, but still feel that they are 4 seperate entities and therefore, should not be combined. Can anyone point me to a regulation/law that can back up either our or his argument?

If you can restrict access to view only, there should not be a problem.

The problem is BSA recordkeeping requirement if you allow Funds Transfers between account. Your system may not be able to retain the required information in an easily retrievable format.

Al

We are exploring allowing consumers who use our consumer online banking product the ability to send money via ACH to owned accounts at other FI's. Our problem is we have a lot of "co-mingled" enrollments on our consumer online product. We have business customers and personal customers enrolled in the product. Add to this the fact that we have allowed business/personal customers to fully link their related businesses & personal accounts to an existing profile. I feel as though we should not allow this service but I can't fully explain why. I'm meeting opposition everywhere I turn. Can someone perhaps explain to me why this is a compliance issue?