Mobile Act Affects Online Account Opening

By: Jeremy Clifton, CRCM, CAMS

If your institution offers online account opening, the Making Online Banking Initiation Legal and Easy (MOBILE) Act will possibly affect how your institution retains documentation for CIP purposes. The MOBILE Act officially became law on May 24, 2018 and clarifies that institutions can obtain scanned copies or images of identification cards (e.g. driver’s license or other ID cards) as part of a request to open an account in an online environment. However, the institution is required to delete the image or copy of the ID card after the institution has obtained the required information from the ID card. This will be a change to some institution’s CIP procedures where copies of ID cards were retained for CIP record keeping but remember these rules only apply to accounts initiated via online channels.  As applicable, institutions should consider updating their CIP program to comply with this act.