Do NOT open an account or accept an application if you cannot form a reasonable belief that you know the true identity of the person seeking to open an account.
DO NOT accept documents containing handwritten information or corrections with whiteout.
To open a new account for an IOLTA , do the following:
Beginning Process
- If the client is new to CCB, meet him or her in person.
- Ask the client to complete the Client Profile sheet. Once completed, review and discuss immediate and future needs and expectations.
- Place the Business Account/Cross-Sell Information sheet facing the client. Ask the client to complete the bottom portion of the sheet. Then assist the client in selecting the account that best meets his/her needs. (For more information see New Account Qualifying Questions.)
- Explain the account benefits including minimum balance requirements and additional services available (Fiduciary Access to Debit Cards and Online Banking Services, Bounce Protection, Mobile Banking, and Bank Direct services).
- For product types, features, and benefits details, see the Product Knowledge Center.
- Cross-sell additional products and services to meet the client's needs using the Personal Account/Cross-Sell Information sheet.
- Discuss office locations, business hours, Instant Issue locations, ITM Locations, and CCB history.
- Depending on the type of client, do one of the following:
New Clients
For all business signers present, obtain an SSN or ITIN and one primary and one secondary or two primary forms of identification from all owners and signers. Note: All primary identification must be valid (not expired) and contain a photograph.
For business signers, not present, obtain their names, addresses, dates of birth, and occupations.Existing clients
Request one form of primary identification. In addition, you can request the Inquiry Identification Code (IIC) from the client.
- Carefully examine the identification for the expiration date, client’s date of birth, photograph, and signature of the client. Note: If the personal identification documentation is not provided, do not open the account. See Detecting Red Flags in ID Verification.
- Obtain required Business Legal Documentation for the type of business.
- Review the Business Legal Documents.
- For Money Services Businesses (MSB), Privately-Owned ATM (PATMO), nongovernmental organizations/charities, or professional service providers, see Specific Business Entity Requirements.
- Identify any Beneficial Ownership.
The query for existing personal CIF
- See CIF Requirements for Business Entities.
- In Xperience > SilverLake > CIF Menu > CIF Inquiry.
- Search by client Tax Identification Number (TIN).
- If you do not find an existing CIF, navigate to Building a Non-Personal CIF.
- For each CIF found, click the client name or CIF. Note: Query the existing account and relationship CIF(s), and ensure the following information is up-to-date:
- Inquiry Identification Code -- required
- Mailing address
- IRS address
- Phone number(s)
- Email address
- Primary and secondary identification information (for example: number, issue date, expiration date)
- In Xperience > SilverLake > StreamLine Platform Menu > Create New Accounts.
- On the Inquiry/Website Selection page, determine if a ChexSystems inquiry is required.
- If an inquiry is required, check Inquire using ChexSystems.
- Click OK.
- The StreamLine New Account Entry page displays.
- Continue to the Opening the Account tab.
Opening the Account
On the StreamLine New Account Entry page, do the following:
- In the Branch field, enter Branch number.
- From the Application drop-down menu, choose D - Demand Deposit Account (DDA).
- In the Platform Type field click the ellipsis
to choose IT - IOLTA Checking.
- Select the product type and click OK.
- In the Account Number field click the ellipsis
to populate an account number.
- Click OK.
- The first CIF pulled into an account will always be the primary account holder.
- Enter the name of the law firm, CIF #, or TIN.
- Click OK. Xperience displays the following message: Existing Customer found.
- Click Select.
- Review the CIF information and update accordingly.
- If the client is using an alternate mailing address, make the appropriate selection and enter information accordingly. For more information see the Alternate Address tab under Address Changes.
- Click OK.
- Delete the client name in the Short name, CIF, or TIN number field.
- In the Short name, CIF, or TIN number field, enter the officer (LAST name FIRST name).
- Be sure you double-check the relationship codes to ensure you are pulling in the correct person or entity.
IOLTA Relationship Codes
- P - Primary (Business Entity)
- T - Alt. SS# (State Bar Foundation/Association)
- O - Prin/Officer (Signer(s))
- Y - SP/DBA/VTX (D/B/A)
- I - Influence (Signer(s))
- Click OK.
- Click Display.
- Click Select.
- In the Relationship Details section, click the ellipsis
then Next Records to choose accordingly.
- Click Select.
- Click OK.
- Delete the client name in the Short name, CIF, or TIN number field.
- Click OK.
- If required, on the Deposits Master screen click the ellipsis
to add an Account Officer Code.
- Click OK.
Line 1 Is this a New Account?
- Click the ellipsis
.
- Select Y Yes.
- Click the ellipsis
Line 20 Class Code
- Click the ellipsis
.
- Based on the specific entity type for the law firm (for example: corporation, LLC, partnership) choose the appropriate class code.
- Click Select.
- Click the ellipsis
Line 30 Initial Deposit Amount
Enter the amount the client is depositing. Note: The initial deposit must be either $50 in cash or in approved checks. This information prints on the signature card.
-
Line 45 Primary CIF Inquiry Code
Enter this code when building the CIF. If the field is blank, ask the client to choose an Inquiry ID Code.
Line 160 Marketing Code
- Click the ellipsis
.
- Select the appropriate code (for example: BB Billboard, CA Consumer Deposit Acquisition, RF Referral, Friend, Family, FB Facebook).
- Click the ellipsis
Line 990 Source of Funds
- Click the ellipsis
.
- Choose one of the following:
- G Existing Client - New $ Bank
- G1 Existing Client - Existing $
- 1N New Client
- Click Select.
- Click the ellipsis
- Click OK.
- Verafin launches in a new window.
- Complete a Due Diligence questionnaire using Verafin. For more information on Verafin click here.
- Xperience displays a message indicating all fields have been verified.
- Click OK.
Line 10 Ownership of Account
- Click the ellipsis
.
- Based on the specific entity type for the law firm (for example: corporation, LLC, partnership) choose the appropriate ownership.
- Click the ellipsis
Line 25 If Corporation - Choose type
- Click the ellipsis
.
- Choose one of the following:
- C - C Corp
- S - S Corp
- N - Non profit
- Click Select.
- Click the ellipsis
Line 120 If NEW Account, was the Verafin Questionnaire completed?
- If creating a new account, enter Y - Yes.
- If revising an account, enter N - No.
Line 140 If Revised Account, was CIF and Verafin Questionnaire Update?
- If creating a new account, enter N - No.
- If revising an account, enter Y - Yes.
Line 260 Is this a Business Account Type?
- Click the ellipsis
.
- Select Y YES.
- Click Select.
- Click the ellipsis
Line 265 Is Business a Foreign Entity?
- Click the ellipsis
.
- Select Y YES or N NO accordingly.
- Click Select.
- Click the ellipsis
Line 270 Is this a Fiduciary Account Type?
- Click the ellipsis
.
- Select N NO.
- Click Select.
- Click the ellipsis
- Click OK. Xperience displays a message indicating all fields have been verified.
- Click OK.
Line 40
Enter the Entity # that you DO NOT want to print on the signature card. If entity #1 and #2 are both Business and/or DBA names, enter 3.
Note: We DO NOT want the law firm listed on the signature card as a signer.
- Click OK. Xperience displays a message indicating all fields have been verified.
- Click OK.
Line 40 Nature of Business
Enter the nature of business.
-
Line 60 County Business Is Located In
Enter the county in which the business is located.
Line 70 State Business Is Located In
Enter the state in which the business is located.
Line 110 Do you have more than 4 signers?
- Click the ellipsis
.
- Select Y YES or N NO accordingly.
- Click Select.
- Click the ellipsis
-
Is A FACSIMILE Signature Allowed? Enter N for No or Y for Yes.
- If you enter Y, then a Resolution for Machine Signed Signatures generates for the client to authorize this type of signature. Obtain a sample of the facsimile signature being used on this document.
- Enter the following on the Res For Machine Signed Sig screen:
- Regular or Special Meeting
- Secretary Name of the entity
Date Regular or Special Meeting Held - MMDDYY
- Enter the following on the Res For Machine Signed Sig screen:
- If you enter Y, then a Resolution for Machine Signed Signatures generates for the client to authorize this type of signature. Obtain a sample of the facsimile signature being used on this document.
- Click OK. Xperience displays a message indicating all fields have been verified.
- Click OK.
- The LODGE, ASSOC, ORGAN RESOLUTION page displays.
Line 10 Lodge, Assoc. or Org. is Non-Profit
Enter Y or N accordingly.
Line 20 Secretary Name
Enter the business secretary / authorized signer's name.
Line 70 Input Y to list Auth Agents A-F
Type Y to list signers on the resolution.
Line 200 and Line 384 A-F Authority for All Agent(s)
Enter a letter for each authorized signer (for example: 2 authorized signers = A-B, 3 authorized signers = A-C).
Note: If the client wants debit cards, both lines should be the exact same.- Click OK.
- List each authorized signer's name and their titles or positions in the space provided.
- Click OK twice. Xperience displays a message indicating all fields have been verified.
- Click OK.
- On the Optional Record Items screen, select all that apply:
- On the StreamLine New Account Entry screen, from each drop-down menu choose:
- View/Print/Email Documents? Select Y - Yes.
-
Upload Account? The system defaults to N-No.
- Click View Documents.
- In the View Order box type 1 for the FL Signature Card to review the signature card for accuracy prior to uploading the account.
-
Another account for these customers?
- Select N - No.
- If there are no more accounts to be opened for the client click OK.
- If the client wishes to open another account (for example: Savings) select Y - Yes.
- Click OK.
- From the Submit to eSign drop-down menu select B - Both eSign and Print for Print Selection items.
- Click OK. A new window opens for eSign. See eSign for more information.
- Ensure the accuracy of the information under the Backup Withholding Certifications section.
- Certify the TIN of the primary owner.
- If the client registered for Online Banking, advise the client that he/she will be required to accept the Online Banking Terms & Conditions when first logging into Online Banking.
- Give the client the welcome packet and all required disclosures and brochures including the Terms and Conditions brochure, the Services and Fees brochure, Truth-in-Savings Disclosure, and Truth-In-Savings Addendum.
- Review the materials with the client.
- Give a copy of the signature card to the client.
- Ensure the client reviews the signature card for accuracy of the information he/she has provided and acknowledges receipt of a completed copy of the form.
- If all documents have been signed using eSign, submit them using eSign. Any documents not submitted through eSign place with the daily work for imaging following the Document Imaging procedures.
- For a resolution, do the following (not every account has a resolution):
- Have the client verify all information on the resolution.
- If a secretary for the business is designated in the provided legal documents, have him or her sign the resolution in the fields indicated.
- Have the designated signers complete the Powers Granted section to indicate that those designated by legal documents or the supporting affidavit have the authority to perform the following acts:
- Endorse checks and orders for the payment of money
- Make withdrawals
- Transfer funds on deposit with CCB
- If the client wants checks, order new checks in Streamline. The client’s account will be automatically debited in 3-4 weeks.
- Accept the opening deposit from the client, which must be either $50 in cash or $50 in approved checks. Note: For opening deposits made by check(s), see place a new account hold.
- Complete the appropriate credit memo ticket for the following accounts:
- Checking/money market account – Checking/MMA credit memo
- Savings/Club account – Savings/Club credit memo
- Complete the following information legibly on the credit memo:
- Date
- Title of account
- Account number
- Tran. code
- Client's initial deposit
- Approved by
- Write the client's initial deposit legibly above the account number.
- Take the credit memo ticket to the Teller line with the new account deposit.
- The Teller completes the deposit transaction and provides a receipt to the client.
- Discuss Night Depository Service with the client.
Quick Reference Guide
Product Type- IOLTA Checking
Legal Documents
Required documentation for IOLTA accounts is the same for Florida, Georgia, and Alabama.Obtain all of the following:
- Notice to Financial Institution form
- Evidence of formation of the business entity (for example: Articles of Incorporation, Articles of Organization, Partnership Agreement)
- Alabama -- from client
- Florida -- from client or FL state site
- Georgia -- from client or GA state site
- W9 Florida Bar Foundation (Florida ONLY)
- Signed and notarized CCB business affidavit (required for all revised accounts)
Click here to access the Business Affidavit Reference Guide.
See Reviewing Business Legal Documents for more information.
DeleteVerafin
Certification of Beneficial Owners of Legal Entities is REQUIRED FOR ALL NEW/REVISED ACCOUNTS
See Business CDD Questionnaire
DeleteCIP/CIF Requirements
- EIN Number for Business Entity
- EIN Number for State Bar
- Alabama Law Foundation Inc. - 63+0951482/CIF# AAA1783
- Florida Bar Foundation Inc. - 59-1004604/CIF# F001884
- Georgia Bar Foundation - 58-055594/CIF# G024451
- Primary & Secondary ID viewed for ALL signers present
- Social Security Number for ALL signers present
- W8-BEN (Non-resident Alien ONLY)
Account Title & Signature Requirement Examples
Title
- JAMES AND JAMES PA
- IOLTA ACCOUNT
OR
- ROBERT JAMES
- D/B/A ROBERT JAMES ATTORNEY AT LAW
- IOLTA ACCOUNT
Signature
- All authorized signers
Codes for Building CIF
-
Class Code
- N - Non-Personal (Specific Entity)
- P - Personal (Signer)
-
Tax ID Code
- T - Business (Specific Entity & D/B/A with EIN)
- N - Non-Reporting Bus (D/B/A without EIN - leave blank)
- U - Foreign Business (Foreign Business Entity)
- I - Individual - US Citizen or Resident Alien (signer(s) present)
- B - Non-Reporting Individual (signer(s) not present)
- F - Non-Resident Alien - ITIN (signer)
- G - Non-Resident Alien - SSN Work Only (signer)
- H - Non-Resident Alien - SSN Non Work (signer)
- E - Non-Resident Alien - No TIN/DOES NOT meet the SPT (leave SSN field blank)
-
Identification Code
- AC - Articles of Corporation
- AO - Articles of Organization
- PA - Partnership Agreement
- Enter 'NA' in the Identification Number Field
-
FinCen Legal Entity - Always Select "Exclude"
- Exclusion Reason
- CV - Capture in Verafin (Business)
- FP - Foreign Person (Non-Resident Alien)
- NP - Natural Person (US Citizen or Resident Alien)
- Exclusion Reason
-
Insider Code (if applicable)
- C - Community Board Member
- D - Director
- E - Associate
- O - Officer
- X - Executive Officer
Codes for Creating Account
-
Account Class Code
- Based on Specific Entity (for example: Corporation, LLC, Partnership - refer to each reference guide accordingly.
-
Ownership
- Based on Specific Entity (for example: Corporation, LLC, Partnership - refer to each reference guide accordingly.
-
Relationship Code
- P - Primary (Business Entity)
- T - Alt. SS# (State Bar Foundation/Association)
- O - Prin/Officer (Signer(s))
- Y - SP/DBA/VTX (D/B/A)
- I - Influence (Signer(s))
-
Is this a Business Account Type?
- Y - Yes
-
Is Business a Foreign Entity?
- N - No
- Y - Yes (W8-BEN-E)
-
Is this a Fiduciary Account Type?
- N - No