Account Setup- Mobile Application

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Question:

During account setup, we would like for the CSR to setup the mobile app information on the core system. The customer will be able to use the app without having to go into mobile banking and completing a few steps. Should the customer sign any type of disclosure allowing us to do this? Is there anywhere I can find this information in a regulation?

Answer:

You are not going to find any guidance. The question is do you want to give frontline personnel access to this ability? Is this a potential breach of internal controls? What if they set themselves up to give themselves mobile banking access on customer accounts that they know will never request it? It will be a risked-based decision.