I am thinking this is going to be more of a legal question rather than a compliance question, but I thought I would start here.

For our internal bank accounts where bank employees are authorized signers, our operations department would like to just list titles of who has authorization on the signature card rather than the names. In our system, they would list the actual names. They want to just use titles so when someone leaves the bank we are not constantly having to do update signatures on signature cards. There would be no signatures on the signature and they would use a resolution to identify the people in those positions. Can we do that?

Also we have a bank customer who has close to 200 accounts with us. Can the bank list the signers on the account but not require signatures on those signature cards, but rather use the resolution to identify the signers? I know that having signatures on a signature is the customer agreeing to the account agreement.

Any suggestions or comments would be appreciated. I am on the fence about this and would rather not allow this.

You are correct. This is contractual issue that needs to be vetted through legal counsel.

MRS8, what did you ever decide on in regards to your internal accounts? The bank I work at identifies specific employees on the sig cards, and we are constantly struggling to stay current on our internal accounts. I'm hoping to find a better way, and I like your idea.