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#2241599 - 08/26/20 12:48 PM Opening Deposit Account at Title Company
BSA_in_depth Offline
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Joined: Jun 2006
Posts: 95
Texas
Is it common in the industry for a bank to allow customers to open a deposit account at the same time the customer is closing on a real estate transaction and signing their mortgage docs at a title company?

We're considering sending the deposit account opening docs to the title company to be executed at the same time as the real estate closing as a convenience for our out-of-market customers. What risks can you think of that need to be mitigated in this situation?

Thank you in advance!

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General Discussion
#2241600 - 08/26/20 02:19 PM Re: Opening Deposit Account at Title Company BSA_in_depth
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,934
Galveston, TX
Mobile branch banking comes to mind. Also convincing the title companies to take on that responsibility and deliver any required disclosures.
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#2241605 - 08/26/20 02:52 PM Re: Opening Deposit Account at Title Company BSA_in_depth
chenin Offline
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chenin
Joined: Jul 2007
Posts: 2,120
Is there a minimum deposit to open the account? Will the title company collect the deposit? If so, they would need to show that the deposit is federally insured, if your FI is.

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#2241615 - 08/26/20 04:23 PM Re: Opening Deposit Account at Title Company BSA_in_depth
BSA_in_depth Offline
Member
Joined: Jun 2006
Posts: 95
Texas
Great thoughts! My other concerns were privacy related to the deposit account records and any potential RESPA issues that might arise if only certain title companies are willing to perform the function and could that be considered a thing of value.

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#2242100 - 09/04/20 08:40 PM Re: Opening Deposit Account at Title Company BSA_in_depth
TryingtoComply Offline
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Joined: Apr 2013
Posts: 1,891
The West
What if the title company uses a mobile notary?
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