Risks for Online Account Opening (CIP)

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Question:

How are smaller banks, say in the $200M asset size, managing compliance risk when diving into online account opening? I'm very concerned about CIP-CDD-EDD. I cannot fathom never obtaining a wet signature or seeing a check prior to accepting a deposit. Also, asking the CDD-EDD questions online is completely different than in person regarding getting a feel for the customer. Do most banks also open new accounts online for businesses, trusts, estates, etc? Is there a vetted software company that is preferred for this endeavor?

Answer:

Different banks will accept different risks. Some banks are online only and this is all they know. Processes are enhanced and monitoring is more automated and enhanced but I'm certain there were some less desirable customers trying to take advantage of remote business. And if they are out of your market and simply wanting to take advantage of a lesser sophisticated bank, you would be right to be concerned.

There will be many vendors who could assist you. Networking in the BOL forums would be my advice to get some names for who might fit your needs. Expected business and costs for systems are two immediate consideration, but at the end of the day a big issue is what market would you be targeting and what revenue would this generate and what costs would it save. Perhaps building a system that assists existing customers would assist the longer term decision process when new customers are invited in.