We have business customers who want to send wire transfer requests through our online banking. Our bank can set the controls to require that one of the customer's employees enters the wire and another employee approves/sends the wire. (note: for these customers we are already allowing repetitive wires and all of these customers also have a signed wire transfer agreement with the bank.) The difference with these wires is that they will be "free-form"- no pre-set templates with designated beneficiries of the wires. We have a consolidated deposit services operation for 3 banks and are NOT planning on having an officer of the bank approve these wires. As long as the account has collected funds, we will process. Do other banks allow for this type of wire activity?

Are you not going to using software specifically designed for customer based wire transfer processing?

It will be done through online banking. The business customer will enter the information through our online banking system but then we have to manually re-enter the information into FedLine to send the wire. Currently if the business requests a non repetitive wire, we send the information to the bank and the officer on the account reviews it and authorizes that the wire can be processed.

I guess I was focusing on this statement:

"The difference with these wires is that they will be "free-form"- no pre-set templates with designated beneficiries of the wires."

This doesn't suggest to me that your software is specifically geared to handle on-line wire transfers. This probably includes not having all the security processes that you really need to have in place.

We recently instituted a call back on OLB wires given the increase in cyberfraud.

We have issued tokens to business customers who perform wires.

Since we cannot force the customer to implement dual control, we are considering other alternatives to ensure the online wire transfer request is legitimate without slowing down the customer. Tokens are one of our options.

Do you have dollar limit thresholds for the tokens? For example, any wires over $2500 will require the customer to use a token?

Since this commericial customer start with your cash management agreement and review the customer security procedures in it. Talk to the customer, to determine the dollar amount of these wires.

OK, Thanks