We will begin allowing consumers to open accounts online. They will be assigned a user name and password in order to initiate ACH transfers to open the account. (not everyone will fund in this manner but some will) From what I can tell, that qualifies as an access device. This will be a one time transaction, but I do not see any exception in the definition for limited transactions. Does everyone agree with my determination thus far?
This leads to my real question. If the e account opening process qualifies as an access device, how do I comply with 1005.5(a)(1). Does the fact that the consumer completes an application online suffice for this requirement? Is there any guidance on this?