Electronic Account Opening - Access Device

We will begin allowing consumers to open accounts online. They will be assigned a user name and password in order to initiate ACH transfers to open the account. (not everyone will fund in this manner but some will) From what I can tell, that qualifies as an access device. This will be a one time transaction, but I do not see any exception in the definition for limited transactions. Does everyone agree with my determination thus far?

This leads to my real question. If the e account opening process qualifies as an access device, how do I comply with 1005.5(a)(1). Does the fact that the consumer completes an application online suffice for this requirement? Is there any guidance on this?

Does anyone have any input into this? The only ACH transaction that will ever be conducted on these accounts are these one time ACH debits from another bank to fund their new account with us. Does that constitute an access device under the regulation?

I don't understand your question. They are applying for the account on-line. I assume that you are providing a Reg E disclosure regarding this service prior to account opening and funding of the account under the aspices of E-sign.

Additionally, allowing funding of new accounts in this manner without additional security steps is not that wise of a move.

I guess I'm just trying to decide if this will be covered under Regulation E. There will not be any recurring EFT transactions - only this one time credit to the fund the account.

What other security measures would you suggest?

Recent discussion:

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1700735#Post1700735