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Latest Compliance - Online Banking Topics

Requirements for Changing Online Passwords

06/21/2020

Our examiners made the bank change customers passwords to expire on online banking every 60 days. Of course, customers do not like this. Can you tell me what the requirements are on this?

Callbacks for Online Auto-Enrollments?

09/01/2019

Are other banks performing callbacks for customers completing online auto-enrollments? If not, what are the controls for preventing fraud?

What are Prepaid Accounts?

09/24/2017

Is there a second prong that applies to the definition of what is, or is not, a Prepaid Account?

Sending DC to Customer if Current DC not Expired?

12/25/2016

Can a Financial Institution send out a debit card to an existing customer, even if the current card is not expired? The FI would be sending the new card as a marketing tool, so to someone who hasn't used the card in quite some time. What about if it is a credit card? Same question, but is the answer the same?

Fraud Involving 3rd Party FI Transfer of Funds

05/28/2012

We use a Processing Agent for our online banking funds transfer to other FIs. We have a situation where our member initiated a funds transfer via our online banking to transfer funds from another FI to us. These transactions processed as usual. Now the other FI is stating it is fraud. We are trying to determine our liability (funds have already been spent and it is past the 60 days). It was our understanding that the processing agent would verify the supplied information for things like name match. Our member's name isn't even CLOSE to the individual that the other FI says the funds came from. Is this 3rd party responsible for not verifying this information or do we in fact have to pay back these funds at our loss?

Guidelines for Online Banking and Business Acct.

10/03/2011

I am looking for some guidelines regarding online banking. Can an individual add their business or even a business they are authorized signers to their personal account? I would like to have some absolute guidelines.

Change in Overdraft Fee - Notification Method

02/07/2011

We are increasing our overdraft fee. Can I notify my online customer with a simple banner to click on? If not, can I send them an email, or do they need it delivered via snail mail?

Exceeding Transaction Limits Online

10/18/2010

When we have a customer who exceeds the transaction limitations on a savings account due to online transfers, we restrict him from online banking. If he also has a sweep set up for overdraft protection, we do not remove the sweep, since this is not what put him over the transaction limit. Is this a violation of the Reg? Should we restrict him from online banking as well as remove the overdraft protection sweep?

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Most Popular Compliance Content

New Escrow on Existing Loan

10/17/2021

We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?

Military Identification Card

10/17/2021

If a customer presents a military identification card and has no other form of ID, it is my understanding is you cannot make a copy of Military ID's. What other forms can be used? This person does not drive and has no transportation to get to the DMV. He does have an expired TX DL but that is all.

Risks for Online Account Opening (CIP)

10/17/2021

How are smaller banks, say in the $200M asset size, managing compliance risk when diving into online account opening? I'm very concerned about CIP-CDD-EDD. I cannot fathom never obtaining a wet signature or seeing a check prior to accepting a deposit. Also, asking the CDD-EDD questions online is completely different than in person regarding getting a feel for the customer. Do most banks also open new accounts online for businesses, trusts, estates, etc? Is there a vetted software company that is preferred for this endeavor?

List of Board Policies (Regs/Acts)

10/17/2021

I was wondering if there is a list of board policies that financial institutions are required to have (regulation/acts) along with how often they should be reviewed by the board?

New Escrow on Existing Loan

10/17/2021

We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?

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