Under Question 1 on the definition of "account" in the FAQ on CIP requirements, we read, "when the account is a loan, the account is opened when the bank enters into an enforceable agreement to provide a loan to the customer." (Thank you John Burnett)

When is everyone considering a deposit account opened? When the first deposit is accepted?

We generate signature cards with account numbers that are given to RMs to take out for signatures. We may not get the signed cards back for a few weeks. The opening date on our core system could be weeks different from the date the CBO and signature card is signed. How is everyone addressing this?

This may have been addressed in a different thread, but I can't find it right now.

We've instructed our staff not to upload accounts until they have the signed documents in hand. They have the ability to print signature cards ahead of time like you mention. But we are not actually "opening" the account until we have signed signature cards and beneficial owner certifications.

We are doing the same as Frog Lady.