We are looking into offering online account opening and I have been tasked to research how we can do away with wet signatures for signature cards without having e-signature capabilities. We are proposing putting certain signature card language on a document that the customer will have to read and accept. Theoretically I think this would be fine for Single accounts but based on my research so far, we are required to have "signature" cards for FDIC insurance purposes for joint accounts. Part of the signature card language for joint accounts includes choosing what type of multiple party account the customer is opening. Our online account opening vendor does not have logic driven capabilities so I was wondering if there are any other banks that have implemented this and if so how?

You need to be talking to your legal counsel. How can you have a contract with someone with some sort of acknowledgement - electronic or otherwise. What are you going to do for a signature specimen in the case of a forgery claim?

Customer will be required to upload their ID so we will be using that as a signature specimen.

OK, let's step through this slowly. What is the legal definition of an "e-signature"? How does your current operational capability fall short of that standard?

"do away with wet signatures for signature cards without having e-signature capabilities" I'm in Randy's camp about asking counsel. You want a contractual obligation without evidence of an agreement, at least as we generally know them and are accepted in courts.

E-SIGN allows a "sound, symbol or process" but the bank has to be willing stand up in court and defend its procedure or the risks could be very, very high.