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#1288947 - 11/18/09 06:05 PM Online Account opening procedures
The Minion Offline
Platinum Poster
The Minion
Joined: Sep 2009
Posts: 832
Hi All! I am new in Compliance, not banking.

I was asked to research online deposit account opening procedures. Please let me know where I should start, or if anyone can send theirs to me. PLEASE
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In order to insult me, I must value your opinion...nice try though.

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#1289421 - 11/19/09 12:21 PM Re: Online Account opening procedures The Minion
Retired DQ Offline
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Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Make sure that your disclosures are out there. An "I have read these terms and conditions and agree" 'type' of button would be useful. Make sure the consumer has to scroll through the disclosures before they get to click...
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Get your facts first, then you can distort them as you please. - Mark Twain

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#1289427 - 11/19/09 12:34 PM Re: Online Account opening procedures The Minion
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Some topics to consider:

will you restrict this to existing customers or will you open it up to new customers to the bank
will you expand the market area from your current area
will you include consumer and business accounts
will you be going into new states and need to consider state laws
the online aspects of regulations covering your products (TISA, Reg D, Reg E, Reg P, OFAC, BSA, CIP, OFAC, COPPA, FACT Act, etc.)
E-sign requirements
Signature cards - physical cards (yes or no); if no will you allow these customers to have checks...you will have two procedures if a no signature card customer comes to a branch
How will you approve CIP and clear discrepancies
How will you deal with potential OFAC matches
Authentication
Fraud - will need to watch for new things like multiple new accounts being opened that are funded from the same external account
Funding methods-ach, wire, checks?
Account number issuance (secure email?)
Vendor management


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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1289627 - 11/19/09 04:35 PM Re: Online Account opening procedures Kathleen O. Blanchard
The Minion Offline
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The Minion
Joined: Sep 2009
Posts: 832
Thank you for a starting point!!! There are a lot of things to consider...head spinning crazy I get the feeling we are opening it to new customers, not only existing.

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#1289677 - 11/19/09 04:57 PM Re: Online Account opening procedures The Minion
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
If so, I hope you are planning to outsource CIP ID verification to ensure you can properly ID the individual establishing the account or stop the process before it falls into you lap. I can't imagine it working smoothly any other way.

If you haven't gotten that far, I recommend you speak with some online verification services to understand the pros and cons before you move forward. Even if you decide not to use them, you'll better understand what you are getting into.
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#1294578 - 11/27/09 05:19 PM Re: Online Account opening procedures BrendaC
Bobw Offline
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Bobw
Joined: Nov 2006
Posts: 336
New England
We open accounts online and use Umonitor to assist with the CIP and OFAC checks and auth checks too. Meets the requirements with the regulators and have had no fraud that has gotten away from us.
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just my opinion, based on my 30+ years

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#1294613 - 11/27/09 05:47 PM Re: Online Account opening procedures Bobw
The Minion Offline
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The Minion
Joined: Sep 2009
Posts: 832
I'll look into them, thanks
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In order to insult me, I must value your opinion...nice try though.

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