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#1965007 - 09/26/14 03:17 PM online account opening
INOH Offline
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We are doing research regarding online account opening and would like to know what other banks are doing in order to CIP a customer.

I've heard of pulling a credit report and then asking questions regarding the credit history.

What about BSA? don't we need to have copies of the ID and social security card?

help!
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#1965087 - 09/26/14 05:06 PM Re: online account opening INOH
Doug Hendrickson Offline
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I don't believe that the actual social security card is necessary unless your procedures call for it. Most of the online account opening systems I have seen either allow the facility of submitting a scanned copy of your photo id, or faxing a copy of it to a certain number. The system also asks 'out of wallet' questions based on a 'soft pull' (whatever that is) of your credit report.
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#1965140 - 09/26/14 06:35 PM Re: online account opening INOH
RR Jen Offline
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What Doug said. Our system does the CIP portion for us based upon similar questions. But what it wont allow us to do are ask the CDD questions the OCC is requiring. We are asking them via email.
Last edited by RR Jen; 09/26/14 08:57 PM. Reason: I mistyped...it's CDD questions not EDD but close enough in my book
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#1965154 - 09/26/14 07:05 PM Re: online account opening INOH
rlcarey Online
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But what it wont allow us to do are ask the EDD questions the OCC is requiring.

On consumer accounts?? Why? What specific questions are they "requiring" you to ask??
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#1965209 - 09/26/14 08:57 PM Re: online account opening INOH
RR Jen Offline
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Sorry...CDD, not EDD. But they didn't outline the questions just insisted that we gather much more data on consumers than name, ID, DOB, chexsystems, address, etc. We now ask 5 questions along the lines of:

will you be making international wires?
will you be making more than $5000 in cash deposits/withdrawals
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#1965217 - 09/26/14 09:22 PM Re: online account opening RR Jen
Doug Hendrickson Offline
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I'm with RLCarey. We do NOT perform CDD/EDD on consumer accounts until we've had some transactional experience with them. We are examined by FDIC and this has never been a problem.

Even some of the businesees say they're going to do certain transactions just in case they want to in the future. While I may risk rate them a bit higher than others, if those transactions don't arise, why carry them as high-risk?
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#1965238 - 09/26/14 09:51 PM Re: online account opening INOH
RR Jen Offline
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It became a BIG issue with the OCC in January.
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#1965242 - 09/26/14 10:02 PM Re: online account opening INOH
Doug Hendrickson Offline
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Seems to me that should re-read Appendix K(?) of the exam manual where they have the chart of customer risk versus due diligence and suspicious activity monitoring.

Resident Consumer Accounts are at the low end, have a basic profile and a generic threshhold monitoring. If you then find that they are actually using higher-risk products (wires, ACH origination), then you can start CDD.
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#1965255 - 09/26/14 11:10 PM Re: online account opening INOH
Kathleen O. Blanchard Offline

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The OCC is relentless on this topic.
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#1965262 - 09/27/14 02:02 AM Re: online account opening INOH
rlcarey Online
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And the OCC, unless challenged, will back banks into corners in which they will never emerge.

Don't stand for it for a minute. I have never seen an OCC bank that has actually pushed back get backed into such a corner.

Push this stuff up the line and call the ombudsman. The OCC field examiners are notorious for these types of demands that never make it into the ROE and they are actually all one examiner's opinion.

Some of these requirements represent considerable costs to the bank.
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#1965307 - 09/29/14 01:59 PM Re: online account opening INOH
RR Jen Offline
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I did not push this issue that hard. When I attended the western outreach conference in Omaha, before receiving our final exam report, the lead OCC compliance examiner for the district indicated this was expected throughout their area. The majority of the banks in the room had already implemented similar questions in the consumer account opening process.
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#1965384 - 09/29/14 04:50 PM Re: online account opening INOH
INOH Offline
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who are the vendors you guys are using for online account opening?
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#1965385 - 09/29/14 04:51 PM Re: online account opening INOH
RR Jen Offline
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We use Bankvue's INMO...they have partnered with WK for disclosures.

http://www.bancvue.com/online-marketing/inmo.html
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#1965392 - 09/29/14 04:59 PM Re: online account opening INOH
INOH Offline
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Northeast
Our policy requires to obtain a copy of the DL plus one additional piece of ID such as their social security card.

I'm not sure if I'm understanding the verification through non documentary methods mentioned on the BSA manual... does it mean we can do online account opening without obtaining the copies of their ID's as long as we verify the information provided by the customer through a credit report, public database, or other source?

if we did that for online account opening, wouldn't we have to change our policy and do the same for accounts opened in person?
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#1965402 - 09/29/14 05:24 PM Re: online account opening INOH
RR Jen Offline
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We created a slightly different procedure for online account opening versus in person to accommodate for this.

We do not get a copy of the ID when opening the account online, but we notate the account and try to get a copy the first time they come into a branch.
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