We are a 7 branch bank with over $400 million in deposits and even when we were a $200 million bank we had written account opening procedures. You want to make sure you have in writing when disclosures are to be given and which disclosures are given. We are an OCC regulated bank - if it's not written down, in their minds, we don't do it!
Opinions are mine and not necessarily those of my employer.
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The paradox of planning is nothing happens....