I guess my question was not clear. We want to offcer on-line banking. I wanted to get some ideas on how you are handling your CIP procedures for those of you that offer to open accounts on-line. thanks!

We offer customers to go online and "request" an account with us. We get a report and run it against a fraud report product we have and against OFAC. Once all looks good we send welcome letter to member requesting further IDs and a signed signature card. All information requested need to come back to us within a certain time frame or else we close account. Best practice is to have seperate procedures in place for on-line accounts and with all the "do's" and "dont's" and link it to your current CIP.