How are smaller banks, say in the $200M asset size, managing compliance risk when diving into online account opening? I'm very concerned about CIP-CDD-EDD. I cannot fathom never obtaining a wet signature or seeing a check prior to accepting a deposit. Also, asking the CDD-EDD questions online is completely different than in person regarding getting a feel for the customer. Do most banks also open new accounts online for businesses, trusts, estates, etc? Is there a vetted software company that is preferred for this endeavor?
What is the bank's responsibility when it comes to online banking fraud? We have a customer, his niece got ahold of his account number, signed him up for online banking, sent out P2P payments to herself and others, and now he's negative in his account. He did file a police report against her. Does this fall on the customer or the bank?
When an online deposit account request is declined, is the denial notice provided required to be dated?
What documents do we need to open accounts to be in compliance for non-resident aliens other than the regular documents (CIP etc)?
Can a business be listed as a Pay on Death beneficiary on a personal account? Along the same line, can a trust be listed?
In the August 30, 2020, Weekly Banker Briefing there was a question regarding receiving scanned driver's licenses when customers open accounts online. The last sentence of the response said the financial institution must delete the copy or image after use. I don't see that in section 213 of the Economic Growth, Regulatory Relief and Consumer Protection Act. Where can I find information regarding the requirement to delete the image?
How do you know when to use a regular children's savings or to use the TX UTMA type of account?
Would it be considered co-mingling of funds if a customer is making business related purchases on the personal account?
Our private banking area is requesting to add two higher balance tiers on an investment savings account. There is no regulation or rule that would hinder this correct? The only thing I can see is if we are not offering this to other bank customers, but only to these high end customers.
We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.