Does anyone allow customers opening new accounts or setting up treasury services to provide the signed documents back as scanned or faxed copies in lieu of originals? For instance, if signers are located on other sides of the country, can they email the sig card to signer 1, they print and sign, then scan and email to signer 2, the print and sign then email the doc back to us? We have gotten blessing from legal, but wondered how many banks are actually doing this as an accomodation to customers.

I would just take a look at how you are performing CIP when soemone is not present... Other than that, I don't have a problem if we already have a relationship with the customers.

How are you making sure that the actual person signed the document(s) and that this is not phony...someone working in collusion with the person that actually appeared at your bank and not the person whose name is being used? This can get tricky. If you have a strong CIP authentication it can lessen the risk but a relative could have the info to answer all online questions correctly.

You can never protect against everything, but at least think through the risks of making sure you area dealing with whom you think you are.

These are commercial accounts, not personal accounts. And we have to have a relationship established with this customer prior to allowing this.