Good Morning Everyone,

I usually handle BSA/AML related matters but I was tasked to investigate considerations for our bank finally opening accounts online. Aside from the risks involved, I am just looking for some checklist type help on what I should be researching for this project.

Among my list of considerations so far is:

- Normal Account Disclosures (Reg E, CC, TIS, etc)
- How to Collect CIP/verify identity (Any comments or normal practices on this would be helpful)
- E-Sign

Are there any NEW disclosures that need to be provided outside of E-Sign related disclosures? How do you normally collect CIP for online account openings? Any other considerations or information I should be researching?

We would restrict deposit account openings to what is equivalent to zip codes in our CRA assessment area since we are local and small.

COPPA. Do you want to open accounts online for sub-teens? If not, how will you block any attempts and redirect children + parents to a physical bank location?

For COPPA, a lot of the softwares out there can block an applicant that enters an age you determine (we just follow the minimum age we open accounts for, which is over 13). Generally you can weed out other applicants your bank may not accept due to risk, such as PEPs.

Patriot Act is another to consider. Don't forget triggered terms if the website advertises rates and other promotions. You'll also want to consider the process your bank wants to take on signature cards. Will ESIGN cover your adverse action notices or will they be mailed?

There's a lot to consider - I haven't ever come across a checklist, but would be happy to talk offline if you wanted to get into specifics.

We don't plan to offer credit products online at this time which may help at least get our feet off the ground and get experience with the account opening process online.

Thanks Monster and Rich, maybe I will reach out once this project starts to ramp up.

Anything else from a broader view to just keep in consideration?