The risk assessment for implementing a debit card program researches types of risk that may impact the bank’s operations, security focuses, and even compliance with Regulation E. The group’s risk assessment under this scenario identifies the following risks:
• Obtaining compatible, reliable, affordable, security-oriented, effectively implemented, and regulatory compliant software.
• Keeping current with industry enhancements, regulatory changes, and software changes.
• Errors in or failure of software.
• Debit card disclosures and/or periodic statements that are inaccurate.
• Advertisements that are inaccurate.
• Vendor training/support that is inadequate.
• Internal training/support that is inadequate.
• Learning curve will push time limits of personnel and customer service will suffer.
• Employees will disregard the Regulation E requirements, resulting in violations.
• Board and management will be unaware of security and compliance requirements with debit card or have little understanding of them.
• Current bank procedures will not encompass Regulation E.
• The scope of internal or external audit will not include debit cards and related issues of Regulation E.
CRCM, CLBB, AAP