About Minor Enrollments

Minor applicants under 13 years old cannot enroll in Digital Banking due to regulatory restrictions. When enrolling, if the birth date entered is not eligible, an error appears and the minor will not be able to continue enrolling.

Regulatory Restrictions

These restrictions vary by country, but in the United States, three primary regulations include the Children's Online Privacy Protection Act (COPPA), the Uniform Transfers to Minors Act (UTMA), and the Uniform Gifts to Minors Act (UGMA).

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.

UTMA and UGMA govern the management of custodial accounts. These acts provide a way to transfer property to minors without the need for a formal trust and designate a custodian to manage the assets until the minor reaches the age of majority. Some requirements include:

• Custodial Accounts – Digital banking accounts for minors under 13 are typically set up as custodial accounts under UTMA or UGMA, where a parent or guardian acts as the custodian.
• Restrictions – The custodian manages the account and has control over the transactions and decisions related to the account until the minor reaches a specified age (usually 18 or 21, depending on state law).

Each state's government website may provide details on how UTMA and UGMA are implemented in that state.

Financial institutions must implement stringent measures to comply with the above regulations, including obtaining parental consent, providing custodial account structures, 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 core banking system and Narmi is limited by what your core supports. Although users must be at least 13 years old, 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.