Do you allow business owners to see their personal accounts with your Business Online product?

Can they transfer between business and personal accounts?

Thanks

We have them maintain seperate logins for business and personal. We do not allow tranfers between business and personal accounts.

I believe we only allow sole proprietorships to link their business and personal accounts. This is disclosed in the online user agreement.

We allow it. It's not something that I (the Compliance Officer) approve of. In our business online banking agreement, we state that we place their personal accounts on their business online banking page to view, but they are not to conduct/transact business on their personal accounts through online banking. Although the agreement doesn't really mean anything or prevent them from doing it. The most recent issue we've run into is in regard to estatements, our core processor complies with esign for electronic signup, disclosure, consent, etc. on our consumer online banking side, however, they do not have this in place for the business side. Therefore, customers that have been using their business online banking to view their personal account information and want estatements now, we can't comply. Our only resolution has been to "force" them to sign into our personal online banking and sign up/consent to the estatements. It's caused some confusion and frustration from our business customers and staff, but that's one of the things that you run into when you start allowing these types of things. If you can convince management not to allow this, you will be much better off as this is only one type of issue that you're going to run into.

I would allow only for sole proprietors to avoid any potential allegations that the bank assisted in misappropriation of company funds.

"In our business online banking agreement, we state that we place their personal accounts on their business online banking page to view, but they are not to conduct/transact business on their personal accounts through online banking. Although the agreement doesn't really mean anything or prevent them from doing it."

Telling them they can't but giving them access to do it puts the bank squarely in the center of the bullseye.

I agree 100%, and I have let Exec Mgmt know that. But you know how some Executives are, they don't want to believe you until something happens, because they think "that will never happen here". Then when it does (which is only a matter of time) they'll act like they had no idea. Which is why I document everything. And each time something comes up, I get to say "well, I told you so". Unfortunately, nothing will change until that arrow hits the bullseye.

I can think of another way of putting that.

If more banks were proactive, than reactive, there would be fewer problems. Isn't this what risk management is about?

Are you saying there is an issue because your business online vendor does not provide eStatements - or that they do provide estatments - but the rules for business and persoanl estatements are different?
I am not a compliance person which is wy i am asking.

We are wanting to allow online transfers between personal and business accounts. What risks do I need to be aware of?

With us it depends on how the business is set up. If a single owner wants his business combined with his personal then fine, and we allow transfers. (What's the difference in writing a check to transfer vs an online transfer? Audit trail is there either way.) If you have multiple owners or if a business wants an office manager to have access, then we don't combine business and personal access. And it is always at the customer's request and the issues that could happen are explained up front and are generally detailed in our Commercial Internet Banking Agreement.

In general, our policy is that we only allow it for sole props. In practice, we have made exceptions on occasion. Like Andy said, it's all about risk management. At some point in the near future, I suspect it will be more of the norm than the exception.