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From a BSA standpoint, opening accounts online can represent risks related to a credit union's Customer Identification Program (CIP) and Know Your Customer requirements. Generally, a credit union's CIP program is based on its own risk assessment and not prescriptive requirements.
But this is changing, thanks to innovative new technologies. In this episode, we're discussing how credit unions can now incorporate these available technologies to produce easier, faster OAO and onboarding that delivers a satisfying experience to members, prospective members, and even staff.
A member opens up a checking account online; and; The member intends to fund the opening of the account with an ACH debit transfer initiated by the credit union.
As members and prospective members increasingly rely on smartphones and other digital devices for many – if not most – of their needs, financial institutions are seeking to deliver effective online account opening and enrollment.
The PATRIOT Act and federal regulations require each credit union to implement a written Customer Identification Program (CIP) that includes certain minimum requirements, such as the collection of identifying information at account opening and risk-based identity verification procedures.
Online deposit account opening rules detailed. April 27, 2012 – Credit unions that facilitate online deposit account opening for members have several sets of rules to satisfy, and attorney and consultant Rob Rutkowski explained these for participants of NAFCU's April 25 webcast.
However, the wording of this law seems to indicate that, when opening accounts online, it is a requirement to delete a copy or image of a member's identification card after using that copy for one of the following: Verifying the person's identity; Verifying that the identification card is authentic; or
Key Takeaways: [01:46] Online account opening - if you just allow that account opener to become a member and there are no checks and balances behind the scenes before you approve them as a member, it is not if, but when you are going to get hit by fraud.
A new NAFCU Compliance Blog post out today explains whether credit unions can place a hold on ACH debit transfers that will be used to fund the online opening of a checking account.
Privacy Notice at Online Account Opening Question - When opening an account online, must we include the privacy notice online or must we subsequently mail our privacy policy to the new member with other account information?