We are looking into opening accounts that are not done face to face. I would really appreciate some guidance on this regarding best practices and for those that have gone through an exam what the regulators have given their approval to. I realize every bank's procedures can differ and that each bank must follow their own CIP procedures; however, we are only in the beginning stages of implenting this so we don't have any written procedures yet and are wanting to see what has worked for other banks. Is there a checklist that anyone uses or written guidance that would be helpful? Thanks for the help.

Your procedures will be heavily dependent on the systems you utilize to support the process. When we were looking into it (before our bank was purchased by another), we were going to use a vendor that automatically performed CIP verification. If information was provided by the applicant that deviated from the info existing in standard consumer reporting databases, the applicant was directed to come in to a branch for assistance. If basic identifying info matched (name, address, etc.), the account application process continued online.

I apologize but I can't remember the name of the company. I'm sure there are many of them out there that do this.