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Online Accounts & CIP

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Question: 
We are looking at an e-banking product that allows accounts to be opened and funded without the customer ever coming into a branch. How do we satisfy the CIP requirements for account opening if we never meet them face to face?
Answer: 

There are numerous ways to complete the CIP requirements. CIP requires you to have a reasonable belief you know the true identify of the customer. Sample, adequate "non-documentary verification" includes:

  1. Contacting a customer (via phone, mail, in person visit, etc.);
  2. Checking credit references with other financial institutions;
  3. Obtaining a financial statement; or
  4. Comparing to credit reports or other public database information (Chex Systems, Telecheck, internet databases, etc.).

Credit reports are an excellent way to verify a person's identity as they typically include all four of the identification requirements. Additionally, they are difficult (or impossible) to counterfeit. I might be able to give you a fake driver's license and you may never know the difference, but how could I pull a credit report on me that I have some how altered? Remember, verification can be completed after the account is open, so you might include mailing something (such as a welcome letter) to the customer at their requested address or asking them to sign and send it back to you. This would verify the address. You will need to ensure your CIP procedures are revised and approved to include these new methods.

First published on BankersOnline.com 11/05/07

First published on 11/05/2007

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