Some questions for your to consider/risk assess before making this change:
How would you obtain a new signature card for the new account?
If the CIP (i.e. Driver's license) you have on record was expired/outdated, how would you obtain the proper CIP on the new account?
Can you positively ID your customer by phone to your satisfaction?
Is there a potential for fraud?
Is there a problem with the customer possibly performing transactions on the "new" account before they have received the disclosures? What if there's a fee that they are assessed before you've even disclosed the fee to them?
I'm not sure I'd be a fan of this idea. We'd have to think it through and risk assess it. We don't currently allow this.
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"Gratitude makes sense of our past, brings peace for today, and creates a vision for tomorrow." - Melody Beattie