If you have the CCH Regs on CD, I'd do some keyword searches to find useful articles on this from the ABA Compliance Magazine. You need to define your scope in the beginning. Will this entail Web sites, Internet banking or both, and E-sign/UETA agreements.
You may want to call Sheshunoff and/or Alex Information. They have manuals, as do other vendors, I'm sure, on managing technology risk and Internet banking.
This will not only provide you with information, but sample policies and procedures.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell