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#1811869 - 05/07/13 06:38 PM Force re-open account
Banker57 Offline
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Joined: Jul 2010
Posts: 439
Minnesota
Can anyone direct me to information on how to handle a closed account (by the customers request) and subsiquent force re-open for a deposit? I believe that the only correct way to re-establish this account is to have the customer sign new documents and provide new disclosures.

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#1811871 - 05/07/13 06:42 PM Re: Force re-open account Banker57
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,893
Illinois
Quote:
subsiquent force re-open for a deposit?


You should not be forcing open an account at all. If the customer consents to reestablishing a relationship with the bank (and bank policy permits the reopening of the same account number) then new docs/disclosures would be required. Also if there is a break in the customer's relationship with the bank, they would be considered a new customer and subject to CIP requirements as well.
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#1811891 - 05/07/13 07:22 PM Re: Force re-open account Banker57
Banker57 Offline
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Joined: Jul 2010
Posts: 439
Minnesota
How about an account that was closed after it has been 'fee-d out' to a zero balance and then closed?

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#1811894 - 05/07/13 07:31 PM Re: Force re-open account Banker57
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Best practice -- open a new account. Minimum acceptable: New account documents, use old account number if your system allows it. But if the account was closed and the customer had no other accounts open with you, this is a CIP event, and a BSA/AML violation if you don't do the CIP dance with the customer.
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#1812061 - 05/08/13 01:24 PM Re: Force re-open account Banker57
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If an account is closed then, regardless of who closed it, it's still closed. As another has pointed out elsewhere, you do not re-open a closed account, you simply recycle the account number. It's a lousy practice whose best supporting rationale is laziness...
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