We plan to open accounts online. We will include a switch kit where customers opening their accounts online can provide ACH info to transfer accounts. Do we need/will we be expected to have a multi-factor mechanism for this one time transaction?

My guess would be no. Unless your account opening process is actually able to go through the CIP and OFAC process, open the account automatically and then actually transfer the funds without any human intervention from the bank. If the process involves just submitting forms that bank personal then handle from there, I would think as long as the web site is secure (SSL)then you should be OK.

Fraudhorn..our expectations are to complete the entire account opening and funding part of the process over the net. We will offer custs. the option to come to a branch but this will not be required. Sig. card will go out to the cust. for signatue but the application and funding - all over the net. So,...multi needed in this case?

I guess the issue is if the system lets them return to the account opening process. For instance, save it (assuming they have created a user name and password) then come back to finsh it at a later time. Then there is potential for having their user name and password compromised by an unauthorized person. Even then...? I would hope the answer is that it is not needed, but I know.

anyone know of any compliance related issues if we have a switch kit/account application online for customers to print, but which must be brought into a branch to actually open the account?

If you're trying to do anything with E-SIGN you won't have demonstrable consent. If all you want to do is deliver materials over the net, you're good with online disclosures as needed and when they're in the lobby, you can complete the opening or take it to the next level, upselling products and services.

What on-line disclosures are required? If we are not opening the account online, is there anything else required besided the Member FDIC and other website stuff (like privacy policy and security)?