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 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?
Is it a requirement for a state chartered credit union to post CIP notices on their website? We have it on the membership form on the website but not on the website itself. Compliance wants to get it put on, but Marketing is refusing because of what they call, "esthetic considerations." Where I can find the text on this topic?
If I sell gift cards at my teller window and/or at a merchant’s location, am I required to get new account data such as TIN and driver’s license numbers?
We are considering making loans via the internet. I know CIP and internet security need to be arduous. What other considerations and compliance issues are there?
We're officially looking to begin internet banking... finally. We're a small, one location bank. My initial question is this - how can we sign up new customers from across the state (or nation) under CIP?
I have been told that the employees in charge of on-line banking are considering allowing wire transfers through our new on-line banking product. What kind of compliance and security issues should they consider when they are designing this product? We are new to on-line banking so my feeling is that we should learn to crawl before we run. Some of the bigger banks do not have this on-line banking feature. How does our midsize bank think they have the resources and the knowledge to accomplish this?
Question: We know that records must be maintained for our Customer Identification Program. We are debating how to do this. Do you have any advice?
Commonly cited violations have long been a source of important information for the design and management of compliance programs.