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#656357 - 12/22/06 04:21 PM any laws regarding out of state customers?
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
We are located in one state. We wish to accept deposit account applications online from new customers from other sttes, should they so choose. I think there is no problem doing this as our documents will state our home base state law applies but....am I wrong about this? Do we have to be aware of each state's additional laws and regs....

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eBanking / Technology
#656407 - 12/22/06 05:36 PM Re: any laws regarding out of state customers? Trees
Kevin Martin Offline
Junior Member
Joined: Jun 2006
Posts: 43
PA
Are you a state chartered bank or National chartered bank?
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#656646 - 12/22/06 09:05 PM Re: any laws regarding out of state customers? Kevin Martin
Trees Offline
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Joined: Apr 2005
Posts: 4,013
state chartered.

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#657405 - 12/26/06 10:19 PM Re: any laws regarding out of state customers? Trees
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Cross state deposits usually do not present any such issues (lending to other state residents may present some issues). Appropriate CIP procedures would be my major concern.
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#660178 - 01/03/07 02:13 PM Re: any laws regarding out of state customers? rlcarey
YHWB Offline
Platinum Poster
Joined: Apr 2005
Posts: 636
Out there
I opened a savings account on line with one of the large banks, and they provided several different Reg CC notices, and Privacy Notices. Also, there is and FFIEC IT Examination Handbook titled "E-Banking" that helped me. Last, I would think your BSA/AML program would need to include this in your risk assessemnts.

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#660261 - 01/03/07 03:38 PM Re: any laws regarding out of state customers? YHWB
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Thanks for your helpful hints!

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#660301 - 01/03/07 04:12 PM Re: any laws regarding out of state customers? Trees
homestar Offline
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Joined: Feb 2001
Posts: 2,245
US of A
Trees, you'll can't just ignore the other state laws. For example, you must usually follow the unclaimed property laws of the state where your customer lives, however, if your home state has reciprocity agreements with other states it might make your job easier.

Also, different states have privacy breach disclosure laws related to their citizens. In other words, if you have a security breach requiring customer notification, you better make sure you're OK for each state where the affected customers live.
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#664701 - 01/11/07 03:48 PM Re: any laws regarding out of state customers? homestar
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Homestar & others - thanks for the points to consider. I am trying so hard to have our folks limit accounts opened on line to our market (state). The more points we need to consider, and that I can show our peeps, the better. If you think of more, please let me know..

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