Good Morning Everyone,
I usually handle BSA/AML related matters but I was tasked to investigate considerations for our bank finally opening accounts online. Aside from the risks involved, I am just looking for some checklist type help on what I should be researching for this project.
Among my list of considerations so far is:
- Normal Account Disclosures (Reg E, CC, TIS, etc)
- How to Collect CIP/verify identity (Any comments or normal practices on this would be helpful)
- E-Sign
Are there any NEW disclosures that need to be provided outside of E-Sign related disclosures? How do you normally collect CIP for online account openings? Any other considerations or information I should be researching?
We would restrict deposit account openings to what is equivalent to zip codes in our CRA assessment area since we are local and small.