After closing (frequently the next day), our loan customers want to open depository accounts for which we have to complete new BO Certifications. We are considering confirming information then providing completed BO certifications in DocuSign for the individual opening the account to initial by each section confirming the information is correct and then e-sign. Does this comply with the substantive requirements of the CDD Rule or could this be an issue with examiners?

I think I'd want the certification form signed when they open the loan account since its a new account. And then for the deposit account opened the next day since that would be another triggering event. Unless I'm missing something that exempts loan accounts.

We have a certification each time an account is opened. I was asking about us completing the certification and have information confirmed and signed via DocuSign? So after the loan is signed and we already have the certification and nothing has changed the next day, it would be an easier process if we already have the information to just prepare the certification and the customer would initial each section and then sign electronically via DocuSign.

I wouldn't see a problem with automating the process as long as your staff knows to ask if the information on the form has changed since the last account was opened and the customer is attesting to the accuracy of the information.

Thank you. We will be sure to have written procedures.