by Randy Carey:
You are asking a legal question - you need to ask your legal counsel.
by Richard Insley
This is an incomplete, and therefore meaningless, question until you add: "...with the following laws/regs--____, ____, ____ ... ____?" Fill in the blanks and you'll see which parts of your question are already answered by your bank's policies/procedures. As Randy says, discuss whatever's left with your legal counsel.