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#2302336 - 10/08/24 02:12 PM Electronic Signature on Signature Cards
Izzy McGarvey Offline
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Joined: Jun 2024
Posts: 15
Right now our bank still requires in person, wet signatures on our signature cards. I would like to gather information on how other institutions handle electronic signatures for cards. We are not currently interested in online account opening. We just want to dip our toes into the modern age at this point. I know the Federal E-sign Act states an electronic signature is just as valid as a paper signature. I am more concerned with our legal responsibility to "know your customer". Also, what do you use as a specimen signature? Any input would be appreciated!

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General Discussion
#2302340 - 10/08/24 02:50 PM Re: Electronic Signature on Signature Cards Izzy McGarvey
rlcarey Offline
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rlcarey
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Galveston, TX
Not sure what a signature specimen has to do with "know your customer". The real question is when was the last time and/or how often do you rely on an actual signature specimen to make a risk decision? It used to be common, but in today's world I would suggest it is further and farther between.
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#2302350 - 10/08/24 04:30 PM Re: Electronic Signature on Signature Cards rlcarey
Izzy McGarvey Offline
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Posts: 15
Those were really two different concerns. Sorry for the confusion.

For the "know your customer", we are worried about how sure we can be that the person signing is truly who they say they are since they are not in person to compare to their ID. If we gather all the information required to satisfy our CIP does would that be considered "reasonable care" to ensure we know the true identity of the customer?

Then a second question being what do other banks use as a specimen signature? We do occasionally use this if we are suspicious of a check.

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#2302437 - 10/11/24 11:48 PM Re: Electronic Signature on Signature Cards Izzy McGarvey
TryingtoComply Offline
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Joined: Apr 2013
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The West
How exactly do you think you can collect an electronic signature for someone that is not there in person and not comply with E-sign?
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#2302627 - 10/18/24 04:21 PM Re: Electronic Signature on Signature Cards TryingtoComply
Izzy McGarvey Offline
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Joined: Jun 2024
Posts: 15
I don't think I understand your question. Of course we would provide the proper disclosures and authorization before using the e signature. We currently use e signatures for other departments so we are familiar with the requirements. We are more concerned with what we would use as a specimen signature and if our normal CIP procedure would be sufficient to verify identity since the person isn't sitting in front of us to verify the signature.
We would likely still use a physical signature for the customers that are in person. We would use e signatures for our customers who are not able to come in and sign.

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#2302629 - 10/18/24 04:39 PM Re: Electronic Signature on Signature Cards Izzy McGarvey
rlcarey Offline
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rlcarey
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Galveston, TX
It all comes down to is if you want a signature specimen, you need them to physically sign a piece of paper. Even if using an electronic signature pad, I can guarantee you it is probably not going to look like a pen and ink signature 90% of the time. There just is no other way.

What any of this has to do with the CIP process, I have no clue.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2302645 - 10/20/24 07:25 PM Re: Electronic Signature on Signature Cards Izzy McGarvey
ACBbank Offline
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New York City
If your policy allows for it, CIP can be completed through documentary or non-documentary methods. When we open an account online, identity verification is completed through non-documentary methods, the individual agrees to our T&C's, and then electronically signs the account agreement, signature cards, etc.
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