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Is that a relic of their being a Dutch bank until last year, or did CapitalOne actually change their application process at all?



No, ING Direct USA was always a United States bank regulated by US regulators, it just happened to be owned by a Dutch parent company (and thus ALSO subject to THEIR regulators in some ways). Capital One since taking over and rebranding as "Capital One 360" has not made any major changes to the Know Your Customer process or the application process. As I explained before, the legal requirement is to identify the customer, and there are a variety of different ways to do this which are acceptable to regulators.




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