When we have a non-profit organization our bank titles it like "Jane Doe D/B/A as Girl Scouts Troop 55" and uses Jane's Social Security number. Where I worked at before titled accounts in the form "Girl Scout Troop 55" and used their own tax number. Can accounts be styled two different ways?
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?
We are deciding whether or not to provide e-statements on our internet site. What are the required disclosures needed to provide this service? I understand that the customer can choose whether or not to receive his/her statement electronically.
I'm trying to figure out if CIP is required on the merchants for whom we process ACH transactions. Here's the scenario. Company A (Merchants) sells goods/services on the internet. They send their debit and credit transactions to Company B (Payment Processor), who then in turn sends their ACH files to us for processing through their account(the merchants does not have an account with us). We perform all BSA requirements for the processor because they are our customer, but I am wondering if the merchant is considered our customer as well, or just a customer of the Payment Processor? Should we be obtaining CIP information on the merchants?
Will having the customer log on to internet banking suffice for their digital signature if we want to change the terms of an electronic agreement or make some other product or service available?