I've been searching BOL for this same answer... we're changing from requiring opening accounts in person to allowing online account opening, so this is going to be a big change in our CIP policy.
So can I just confirm with those of you who do online account opening, that:
1) You collect the 4 required items
2) You don't require a photocopy of a drivers license/ID
3) You collect the DL/ID info (issue date, expiration date, and ID#)
4) You run the customer through Chex Systems, and so long as there are no discrepancies, this is sufficient for the examiners?
(And of course this conforms with your CIP policy and is not for what you would determine high risk customers.)