If a FI has never opened accounts in a manner other than face-to-face, what is the process of transitioning to an online account opening process for CIP? I know that a risk assessment needs to be conducted and we are going to utilize our current risk assessment for accounts opened in our "identified" area and anything accounts opened for parties outside our area will initially be high risk. With that being said, we will required the consumer requesting to open an account to supply the four primary CIP items, Legal Name, Physical Address, TIN, and DOB (for individuals), but what do others obtain to conduct a documentary verification? Or do you just use non-documetary means to verify accounts opened online?
The opinion stated here is what it is, My Opinion.