Not sure what category this question should fall under. Employee wants to reopen her old savings account and wants to add her brother so he can have checks direct deposited, but she will have access to the money. Brother doesn't come in, employee justs gives ID information. Apparently he doesn't have a drivers license, just an ID. ID verification comes back that multiple people may be using that SSN. Further checking with ID verification vendor gets the recommendation to be "extremely cautious" if opening an account for this individual. Do we tell the employee her brother has to open his own account, come in with proper ID, etc. or allow her to add him to her account? Since the savings account is her name, other employees would not have access to look at the account.

What do your procedures state? That everyone opening an account must be present? Are these waived for employees? I would suggest that you have the brother come in, and that he also understand that by putting the sister on the account (employee or not) that she can also withdraw funds from the account.

I'd be very wary of acceding to this request. You have red flags from your verification service. Don't make concessions in your policies based on the employee connection.

Your employee may be asking for this in complete innocence. But she should be told that you cannot bend the rules for her brother. And, if you ultimately open the account in his name alone or add him to the employee's account, make sure the employee understands that she needs to maintain a complete "hands off" stance with regard to her brother's relationship to the bank.

I would further add that unless the employee in question has a reason to know about her brothers id problems, you cannot share this information with her. I would follow my internal procedures, in my shop we would explain that before opening the account we need to talk to her brother in person. Get the brother in the bank, let him know you will not open the account due to credit checks, give him the proper denial information and let him tell sis why he does not want to open the account. As an employee or an account holder, the sister should understand the 'joint' in joint account means good or bad she is responsible if her name is attached to the account.

Sorry, forget to login, that last post was me!

Employee wants me to "explain" why it would be a problem to leave the account in her name with brother as joint. Are there regulatory or other reasons why we would not want the employees name first on the account? I don't see a problem with employee having anyone they want to have on their account, but knowing that it is for the purpose of depositing his ACH and then withdrawing cash for him, bothers me.

The point of the warnings in the string above is to suggest a way in which you can refuse to do business with someone whose ID verification attempt has resulted in some red flags.

I repeat others' suggestions that you tell your employee that you won't open the account unless her brother comes in to sign paperwork and confirm his identity. That's a policy decision. Or, if you just don't want to do business with this guy, contact him directly and tell his so. Provide him with an FCRA notice concerning where the adverse info came from and tell your employee to talk to her brother about why the bank won't open the account.

I'll suggest one reason the guy would want to have his paycheck deposited to his sister's account -- he could be hiding from creditors or an ex-wife or other party trying to grab money due them. Do you really want that sort of customer? I'm not saying this guy is that sort of deadbeat, but it's an explanation for the request.

One more thing, in case it comes up. Don't under any circumstances allow this bozo to have his paycheck direct deposited to his sister's account unless he's an owner of the account with full rights. That's just common ACH operating procedure.