Yes, we believe that a federally chartered savings bank may add a minor as an authorized signer to a business checking account when presented with the appropriate corporate documents providing such authorization.

The Illinois Savings Bank Act states that any individual may hold a deposit account at a savings bank regardless of age. Similarly, the Illinois Banking Act states that banks may accept deposits from minors, and the rules and regulations are the same as for accounts held by adults. While we are unaware of any federal statutory provisions, regulations, guidances or letters that expressly address this situation or provide general “wild card” authority that might apply to this situation, we believe that the OCC and Illinois courts likely would take the same approach with federally chartered savings banks.

With respect to documentation, we recommend following your bank’s customer identification program (CIP) policies with respect to the minor as you would with any other new customer or non-customer authorized signer (notably, federal CIP regulations do not address specific requirements for minors).

For resources related to our guidance, please see:

• Illinois Savings Bank Act, 205 ILCS 205/7005 (Any individual “regardless of age” may hold a deposit account in a savings bank)

• Illinois Banking Act, 205 ILCS 5/45.1 (Banks may accept deposits from minors and “the rules and regulations of such bank with respect to each such deposit and account shall be as binding upon such minor as if such minor were of full age and legal capacity.”)

• CIP Regulations, 31 CFR 1020.220(a)(2) (“The CIP must contain procedures for verifying the identity of the customer . . . within a reasonable time after the account is opened.”)