Good Morning --

We are considering offering an "Internet" CD to a specific group of customers, and are wondering whether many banks are doing this.

If so, would anyone be willing to offer any advice in regards to CIP, etc.?

Thanks,

Vicki S.

Maybe there is some confusion as to what I'm asking. What we are intending to do is to allow customers to open a specific type of Certificate of Deposit via the internet. As this is new territory for us, we want to not only ensure that we are following all requried compliance rules, but also that we are following strong safety and soundness procedures.

Vicki,it doesn't look like you have gotten any responses, so I will tell you what we are doing. We permit customers to apply for a CD account through our website. We do a CIP check of the customer before we open the account just as we would with any customer. Funds to purchase a CD can either be wired to our bank or the customer can authorize an electronic debit to their checking or savings account at another bank. We have a special disclosure for CDs that are purchsed this way which specifies that no withdrawals will be permitted for 90 days. Otherwise, the process is very similar to a customer who contacts us by telephone or regular mail. Hope this is helpful.

I agree with Kbee.

Your current CIP procedures for opening accounts at face-to-face level should be the based to tailor procedures for online accounts.

I would definetively conduct a risk assessment as well.

We're going to start offering savings and CD's online through our Online Banking provider and a third-party partner of theirs. We're part way through the risk assessment process and I've looked around for other banks to see how they tackled their risk assessment as well as their procedures for Online Account opening.

The one bank I've been able to contact/discuss the issue with is an online-only bank, and does things a lot differently than we plan to.

Is anyone else doing this at this time? We're going to be using the CashEdge OpenNow/FundNow product.

Any help would be appreciated.

How are you handling the disclosures required at account opening? Specifically the section 230.4(a)(ii)? Is your disclosure (complete with the maturity date) available before the acccount is opened?

Wondering if any of you who were considering were ever able to get comfortable with this and establish some procedures - and if so, would you be willing to share? We're considering opening accounts on-line but are having some trouble getting comfortable with the idea - particularly for new customers.