We're a $700M bank that is looking at changing the way we verify deposit documentation (signature cards, corporate resolutions, etc.) We currently check everything. When a new account is opened, we track whether we've received the necessary documentation and verify that the signature card, etc. match the setup in our core system. Additionally, when new cards are generated, we verify that they are done correctly and any necessary account maintenance has been done.

We are experiencing a lot of internal pressure to ease up. It has been suggested that we "spot check" by pulling random samples, like the audit department does. Or simply leave it to the branch managers to make sure everything is done properly. Problems will be picked up by the audit area. Based on the error rate we encounter, we're uncomfortable doing this. But we keep hearing that this is "small bank thinking", and we're getting to big to operate this way. And NOBODY does this type of verification anymore.

What are other banks doing? And is it working for you? I would be especially interested in hearing about banks our size or larger.

Thanks!

We are over 1B and we do verify...it's hard to comply correctly with CIP/BSA, etc, without knowing the account documentation is accurate and that you have what you need. IT will also enable you to more likely catch improper set-ups such as NOW accounts to ineligible entities, for instance!

We are approaching 10B, and we verify everything. The problem with relying on audit spot checks is that the examiners may not select the same files. I have seen too many cases where banks correct the exceptions in the audit but do not fix the problem and do not do a systemwide correction.

We are $620mm.

The branch management does the intial check, and then customer service does a second total check of the information.

If anything is missing or wrong, it is sent back to the branch to be corrected, and then the process starts over again for that item.

We most likely do more checking and re-checking today than we did just 3 years ago.

My previous $11b bank had a whole back room department dedicated to this review /verification process.

We are approaching $2B and verify everything as well. We even run a TIN check to make sure we won't come back with a mis-match TIN. You would be surprised how long that list of mis-match TINs gets. We also have personnel to verify all IRA and HSA transactions so that we don't end up in a pickle over those at year-end. (I can't believe I just used "in a pickle" in a sentence. It seems apropos!)

Another problem with spot checking and relying on Audit to catch problems is that some of the problems just can't be effectively fixed if they aren't addressed right away. With the current emphasis on CIP and all things BSA, you don't want to be caught with new accounts with missing SSNs, inadequate ID verification, or invalid (post office) addresses.

We're approaching $500 Million and verify everything.

We are approaching 1b and feel it is important as ever to check all deposit decumentation for accuracy and completeness. What a job it would be to clean up an entire deposit customer base if chronic error are uncovered by the regulators. Post 2003 has very much changed the way we do things in operations.

This is so great to hear...we are an $80 million bank (small, I know) but I was checking EVERYTHING on CIP and new account set up, and consistnatly got the "evil eye" from my new accounts girl. Good to know that I am not alone, as misery loves company!

[From Opsgal2]
We are experiencing a lot of internal pressure to ease up. It has been suggested that we "spot check" by pulling random samples, like the audit department does. Or simply leave it to the branch managers to make sure everything is done properly. Problems will be picked up by the audit area. Based on the error rate we encounter, we're uncomfortable doing this. But we keep hearing that this is "small bank thinking", and we're getting to big to operate this way. And NOBODY does this type of verification anymore.


Maybe those asking for the bank to ease up should check out these orders.

http://www.fdic.gov/bank/individual/enforcement/2007-01-01.pdf
See pages 28 and 31.

http://www.fdic.gov/bank/individual/enforcement/2007-03-01.pdf
See pages 2 and 5.

Retread,

We actually track CIP-related documentation separately, and I can't even imagine easing up on this!

What we're receiving the most flak about is the account-specific documentation. We check to make sure the signature cards are completed properly, signed in the correct places, match the way we have the account set up on our system, etc. We also track to make sure we receive a card for each account that is opened.

Any thoughts specifically on that process?

And thanks to everyone for the feedback!

You may be asking the wrong person. I personally think that you can never do enough to verify account opening documentation, and I would think an accurate signature card would be near the top of the most important information you collect. In this day and time you cannot be too careful. We go through a process where all new account documentation is checked for any missing or questionable information. Any exceptions are tracked. If the exceptions are not cleared within 60 days, the subject account is closed. That may be extreme, but it helps keep us out of trouble.