Deposit account opening where every check runs once and every referral says why
Clean applicants open in minutes; every referral says why and is decided the same day.
See one case, screen by screen ↓Deposit account opening is how a bank or credit union takes an applicant from a checking or savings application to an open, funded account: identifying the customer under its Customer Identification Program, checking OFAC and the 314(a) list, reading the screening report, delivering the disclosures and verifying the opening deposit. Deposit Account Opening runs those checks once, in parallel, while the applicant types, opens clean applicants inside limits the bank sets, and sends every other application to a person with one reason and the action the bank's policy allows.
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A checking or savings application passes through a digital account opening platform, an identity service, a screening service, the core and the card processor. Anything outside the happy path lands in a back-office queue as a refer code, not a sentence, and a Deposit Operations specialist re-runs the checks in the core and the screening service to learn why. Meanwhile many applicants give up before they finish, often at the identity steps.
The risk sits in what happens next. Whether an applicant with an old $300 overdraft gets an account depends on who reads the screening report, which is a fair-treatment and UDAAP exposure and lost deposits. A decline based on that report, or a less favorable account offered instead, owes an FCRA adverse action notice that examiners find missing. And card and ACH opening deposits are a favored route for fraud when the signal is seen after the money moves.
Estimated split of a specialist's and a team lead's minutes on one referred application, by hand and with the agents; the 'after' column follows the sample referral, where Kendra opened it at 8:38 AM and approved at 8:42 AM.
Six agents check while the applicant types, a Decision agent opens or refers, a Notice agent drafts; two people approve.
Jordan Ellery of Raleigh, North Carolina, applies for Corvane Everyday Checking on the mobile app on a Wednesday evening. Here is what happens next, screen by screen, in the working solution at Corvane National Bank.
Jordan gives a name and birth date, an ID photo and selfie, an address and SSN, accepts the disclosures, declines overdraft coverage and funds $150 by debit card, then submits at 7:09:45 PM: 7 minutes 40 seconds. In the same minutes the agents check OFAC (clear) and the 314(a) list (no match), verify the license and selfie (match 0.98) and the CIP data on two sources, read the screening report (1 record), deliver the disclosures and hold the $150.
Each agent step shows its result word, Clear, No match, Verified, 1 record, Delivered, Recorded, and a source that opens the passage it rests on.
The screening record trips Corvane's limits L-2026.3, rule 3. The Decision agent writes the referral packet: the one reason, the record, the second-chance test of policy DEP-07 §3.1 passed line by line (not fraud, $312.40 under $500, reported 5 years 7 months ago), and the proposed account, Corvane Restart Checking. Everything else came back clear.
“The deposit account screening report shows a $312.40 unpaid overdraft from an account another bank closed in March 2021. Corvane's limits refer any record from the last 7 years.”
Kendra opens the referral, due by noon. One click on the screening step's source opens report DASR-88213047 with the lines that matter highlighted: an account closed by the reporting bank for an unpaid overdraft of $312.40, reported Mar 9, 2021, still unpaid. She does not re-run a single check.
“Fraud, account abuse or identity misuse records: none.”
The answer cites the limit, the record and the policy: a record inside 7 years refers; this one is not fraud, is under $500 and is more than 24 months old, so DEP-07 §3.1(a) allows Restart Checking. Opening Everyday Checking anyway is an override that needs a reason code, a note and a team lead. Below the answer, the trace shows each agent, its version, result, time and confidence.
Offering a different account because of a screening report is an adverse action, so the Notice agent drafted the offer letter and the FCRA notice together, only in sentences from Compliance's wording W-2026.2. The notice names the reporting agency, Clearwell Deposit Reporting, with its address and toll-free number, says the agency did not make the decision, and gives Jordan the right to a free report within 60 days and to dispute it.
“We are not able to open Everyday Checking for you at this time. We can open Corvane Restart Checking for you instead.”
Kendra approves the offer as maker with reason code R1, Second-chance offer per DEP-07. The packet and notice go to Luis Ferraro, Deposit Operations Team Lead; the person who prepared an item cannot check it. Luis approves at 8:49 AM, and at 8:50 AM the offer and notice go to Jordan in the app and by email, with a mailed copy queued.
“The $150 stays held until Jordan accepts.”
Jordan accepts Restart Checking at 9:14 AM and e-signs its Reg DD disclosure. The Decision agent opens the account in the core (ending 7731), captures the $150 from the held card authorization and orders the debit card. The next-morning strip extends the same time axis from the first tap to the open account, with every person's decision on it.
“14 h 14 min from start to an open, funded account; 34 min after a person first decided.”
Yesterday the Funding agent verified 1,598 opening deposits and held $27,840 for 178 referrals, captured only at opening. Of 24 funding signals, 9 went to Owen Batista's fraud team with their evidence: a card in another person's name, $9,900 split across three cards. A hold is released only with a second person.
Jordan's row now reads Done. Next is Maya Okafor: the birth year on her license (1987) differs from the bureau record (1981), and the agents propose asking for a second ID under procedure CIP-4.3. 63 referrals are waiting, 58 due by noon, and at the team's pace of 31 an hour every noon referral is decided by 10:40 AM.
Standard offers can be selected together and approved as one batch, still sent to a checker.
The same application, seen by the four people who carry it: what their day looked like, and what it looks like now.
Six agents check while the applicant types, a Decision agent opens or refers, a Notice agent drafts; two people approve.
Reads the application as the applicant types, on the digital platform or at the branch desk, and keeps one application record that the other agents work from.
Runs CIP: checks the ID's authenticity and the selfie match, verifies name, date of birth, address and SSN on two sources, and proposes how a discrepancy is resolved under procedure CIP-4.
Checks OFAC and FinCEN's 314(a) list the moment the applicant gives a name.
Reads the deposit account screening report and tests each record against the second-chance policy, DEP-07 §3.1.
Verifies the card's name, address and authorization, validates ACH accounts the first time they are debited, and checks device and velocity.
Delivers the E-SIGN consent, Reg DD account disclosures, Reg E initial disclosures and the privacy notice, records versions and times, and records the overdraft choice.
Applies the bank's limits, opens clean applications, writes every other one up as a referral packet with one reason, the evidence and the action policy allows, and after approvals opens the account, orders the card and captures the deposit.
Drafts FCRA adverse action notices and offer letters from approved wording, checks them for risky words, and sends them after approvals.
Maker decides, a different checker approves. The agents propose; a named person decides.
A specialist can ask about any application in plain words. Every answer cites the limit, the record or the policy it rests on.
Why not open Everyday Checking?
Corvane's limits refer any screening record from the last 7 years. Jordan's report shows one: an account another bank closed in March 2021 with $312.40 unpaid. It is not a fraud record, it is under $500 and more than 24 months old, so DEP-07 §3.1(a) allows Restart Checking. Opening Everyday Checking anyway is an override: it needs a reason code, a note and a team lead.
Is anything about the funding risky?
No. The $150 came from a debit card in Jordan's name; the address matched and the card was authorized at 7:08:44 PM. It is the first application from this device and the fraud signal is 0.06, under the 0.40 threshold. The $150 is held, not captured, until the account opens.
What must the notice say?
Offering Restart Checking instead of Everyday Checking because of a report is an adverse action, so FCRA §615(a) applies. The draft names Clearwell Deposit Reporting with its address and toll-free number, says Clearwell did not make the decision, and gives Jordan the right to a free report within 60 days and to dispute it. Every sentence comes from wording W-2026.2, and it mentions no other check.
13 screens from the working solution, on its sample data. Pick one to see it large.
What the agents may do alone, and what reaches a person, are settings the bank owns. Every change is versioned, approved by a second person and on the audit trail.
| Setting | Default | Choose from |
|---|---|---|
| Screening report (limit rule 3) | No records in the last 7 years | Any record inside the window refers to a person |
| Funding by debit card (limit rule 4a) | Up to $500 | Up to $500 (L-2026.3) · up to $1,000 (proposed L-2026.4, waiting for the BSA Officer) |
| Funding by ACH (limit rule 4b) | Up to $2,500, external account validated | Changed with the limits: Head of Deposit Operations proposes, BSA Officer approves |
| Second-chance eligibility (DEP-07 §3.1) | $500 or less reported more than 24 months ago, or $100 or less at any age; no fraud | Approved by the Consumer Compliance Officer and the BSA Officer |
| Confidence thresholds | Selfie match 0.95 · fraud signal 0.40 · record parse 0.90 | Changed only with a new agent version that Model Risk approves |
| Decision deadlines | Same business day before 5:00 PM; after-hours by 12:00 PM | On · Off; escalate 30 minutes before due to the team lead on shift |
| Assignment | By skill (identity, screening, funding) and due time | By skill and due time · round-robin |
| Retention and masking | Five years after the account closes or the application is declined; SSNs last 4 only | Mask SSNs and ID numbers · GLBA need-to-know access · redact in examiner packs: each On · Off |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample applications · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (industry research on digital onboarding: up to 60% of applicants abandon; a 2025 benchmark of 98 US banks and credit unions: 3.36 abandoned applications per checking account opened online, directional). Rules named as context: 31 CFR 1020.220 (CIP), 31 CFR 1010.520 (314(a)), 15 U.S.C. 1681m(a) (FCRA adverse action notices), 12 CFR 1030.4 and 12 CFR 1005.17 (Regulations DD and E). Corvane National Bank, Clearwell Deposit Reporting and the people named on this page are fictional: characters and sample data in the working solution.
Deposit account opening is how a bank or credit union takes an applicant from a checking or savings application to an open, funded account: identifying the customer under its Customer Identification Program, checking OFAC and the 314(a) list, reading the screening report, delivering the disclosures and verifying the opening deposit. Deposit Account Opening runs those checks once, in parallel, while the applicant types, opens clean applicants inside limits the bank sets, and sends every other application to a person with one reason and the action the bank's policy allows.
Each agent starts its check the moment its data exists: the lists at the name, identity at the ID photo, screening at the SSN. The decision lands seconds after the applicant's last tap, 4 seconds in the sample application. A specialist sees what the applicant did and what the agents checked on one time axis, with a source behind every result, so nobody re-runs a check to learn why.
When a bank offers a different account than the one applied for because of a screening report, the FCRA treats that as an adverse action, as it does a decline. The Notice agent drafts the notice with the offer, naming the reporting agency, stating that the agency did not make the decision and giving the right to a free report within 60 days and to dispute it. It is sent only after a maker and a checker approve.
The Identity agent verifies the ID, the selfie and the CIP data on two sources and proposes how a discrepancy is resolved, but never resolves one on its own. The Lists agent never clears a potential match: OFAC matches go to the Sanctions team, and a 314(a) match is visible only to the BSA Officer, never on a customer letter or a specialist's queue text.
The Funding agent verifies card deposits and validates ACH accounts while the applicant types, and holds the money until the account is approved. A fraud signal over 0.40 goes to the fraud team with its evidence, and a hold is released only with a second person.
Yes. The limits, the second-chance policy, the wording, the thresholds and the deadlines are the bank's settings. A proposed limit change is replayed on the last 30 days of applications, showing how many more would open automatically and how many of those later proved to be funding fraud, before the BSA Officer approves it.
Yes. The agents open accounts on their own only inside the bank's limits. Every referral is decided by a specialist with a reason code and checked by a team lead, overriding the agents' proposal needs a reason and a note, and nobody can check their own work.
The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your limits, second-chance policy, notice wording and a sample of past applications, and it goes live once every quality gate has passed. We will walk you through it on your own applications first.
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1-min demoWe'll run Deposit Account Opening on a sample of your own past applications and referrals.