By default, minor applicants under 13 years old cannot enroll in Narmi Banking. When enrolling, if the birth date entered is not eligible, an error appears and the minor will not be able to continue enrolling.
If your state laws allow it, you can enable minors under age 13 to enroll in Narmi Banking by changing the minimum age requirement in Narmi Command. If you change the minimum age requirement, Narmi’s Master Service Agreement includes a warranty requiring you to comply with applicable law, which includes providing the required disclosures and obtaining the appropriate consents under the Children's Online Privacy Protection Act (COPPA). To change the minimum age requirement, go to Narmi Command under Configurations > Institution settings > Minimum Age for Consumer Digital Banking Enrollment or Minimum Age for Consumer Digital Banking Enrollment.
Regulatory Considerations
Regulation of children’s activities online and in banking varies by jurisdiction, and you should consult your legal and compliance teams before setting the enrollment age for applicants in Narmi Banking.
In addition to federal and state regulations around banking minors and custodial accounts, additional disclosures and consents are required for online banking under COPPA. COPPA is designed to protect the privacy of children under the age of 13 by requiring websites and online services, including digital banking platforms, to obtain parental consent before collecting, using, or disclosing personal information from children. Some requirements include:
Parental Consent – Financial institutions must obtain verifiable parental consent before enrolling minors under 13 in digital banking services.
Privacy Policies – Financial institutions must provide a clear and comprehensive privacy policy outlining their data collection practices regarding children.
Data Minimization – Financial institutions should collect only the information necessary to provide the service and must ensure the security of that data.
The Federal Trade Commission (FTC) enforces COPPA and can take action against institutions that fail to comply with its requirements. This can include fines and other penalties.
Financial institutions must implement stringent measures to comply with the COPPA, including obtaining parental consent and ensuring robust privacy and security protocols. Please contact your Narmi Relationship Manager to discuss defining minors for specific accounts or offering custodial and joint accounts.
Core Restrictions and Segmentation
Digital banking user entitlement flexibility varies by the core banking system, and Narmi is limited by what your core supports. Some cores allow minors aged 13-17 to have their own accounts, while others require a joint adult user.
Your institution can also use segmentation to limit functionalities to minor users. During implementation, your Implementation Project Manager will review your institution's goals around minor users and suggest specific approaches to take based on your core.