We have learned that if a customer has an address outside of the U.S. they cannot use the bill pay feature of our internet banking program. Once their address is changed to a U.S. address they do have access to bill pay. Is this a requirement due to a U.S. banking regulation regarding persons with international addresses and online payments? Or is this simply a voluntary security feature of our online banking vendor?
If our Bank is adopting an account closing survey and they want to send it to closed account customers by text and email, does this fall under the
CAN-SPAM rules? They are only requesting feedback, there is no promotional material.
Are other banks performing callbacks for customers completing online auto-enrollments? If not, what are the controls for preventing fraud?
Is there a rule or regulation that requires banks to make their online banking customers change their online banking password periodically?
We would like to create an easier way for our consumers to sign up for E-Statements. What are the requirements, compliance wise for this? Currently, our customers need to log into their online banking, view a PDF disclosure that generates a "code", and customer then has to type in code and agree to terms and conditions. Compliance wise- can consumers just sign the disclosure/consent in person at lobby?
Are Online Bill Payment checks subject to Reg CC?
Our customer has appointed her daughter as her attorney-in-fact. Can the daughter set up Internet banking on her mom's account? The daughter/AIF is not listed as a joint owner of the account, and was appointed AIF after the account was open.
Can a representative payee on an account have online banking? If the account they are put on such as basic checking offers this service, can they be denied online banking or is this discriminatory?
We are now scanning all of our deposit and loan documents for our customers. Is there any reason to "block" our lenders from viewing all the documents - such as a drivers license? Currently our lenders are blocked from viewing all deposit documents as well as CIF documents - signature cards, resolutions, trusts, drivers license, etc. Our lenders are required to capture the information from the drivers license when completing the loan application. I can remember back when we had loan files that we weren't allowed to keep a copy of the DL in the file. But now that they are scanned, do they need to be "blocked" from certain employees for viewing?
Can we charge a paper statement fee for Money Market accounts?