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#1719821 - 07/13/12 02:56 PM Electronic Account Opening - Access Device
ComplytillIdie Offline
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Joined: Feb 2012
Posts: 196
GA
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?

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eBanking / Technology
#1723156 - 07/25/12 04:10 PM Re: Electronic Account Opening - Access Device [Re: ComplytillIdie]
ComplytillIdie Offline
100 Club
Joined: Feb 2012
Posts: 196
GA
Does anyone have any input into this? The only ACH transaction that will ever be conducted on these accounts are these one time ACH debits from another bank to fund their new account with us. Does that constitute an access device under the regulation?

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#1723164 - 07/25/12 04:21 PM Re: Electronic Account Opening - Access Device [Re: ComplytillIdie]
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 74,768
Galveston, TX
I don't understand your question. They are applying for the account on-line. I assume that you are providing a Reg E disclosure regarding this service prior to account opening and funding of the account under the aspices of E-sign.

Additionally, allowing funding of new accounts in this manner without additional security steps is not that wise of a move.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1723205 - 07/25/12 05:30 PM Re: Electronic Account Opening - Access Device [Re: ComplytillIdie]
ComplytillIdie Offline
100 Club
Joined: Feb 2012
Posts: 196
GA
I guess I'm just trying to decide if this will be covered under Regulation E. There will not be any recurring EFT transactions - only this one time credit to the fund the account.

What other security measures would you suggest?

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#1723232 - 07/25/12 06:04 PM Re: Electronic Account Opening - Access Device [Re: ComplytillIdie]
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 74,768
Galveston, TX
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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