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#1653484 - 01/20/12 02:52 PM Mobile Banking
Auditgirl50 Offline
Member
Joined: Feb 2009
Posts: 62
Texas
We are about to launch Mobile Banking for our customers. We are listing the types of accounts we offer. My question is: under the new accounts tab, we list products out...should we also include the requirements for those accounts?

Also:
Can someone direct me to the regulation or advisory for mobile banking?

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eBanking / Technology
#1653987 - 01/20/12 09:37 PM Re: Mobile Banking Auditgirl50
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
Mobile banking fun...

IMO I would not list the requirements for those accounts... unless I could sign-up for them using mobile banking. If I was able to sign up for them then I would include the requirements. Otherwise it isn't anything more than letting customers know the name of your products.

Reg E is the easiest place to state for mobile banking. Also there is FFIEC guidance... the problem with these is they are terribly outdated and technology doesn't even see them in the rearview. However, consider the overall impact of the product (in terms of Reg E). A lot of people (my bank included) use our mobile product as an almost exact mirror of our online banking. So we treat it very much the same in terms of regulatory guidance. We lock down a few things (no adding payees) to mitigate risk and you can't have mobile without online. However, everybody makes their product different... so follow the intent of the rules, because there is not a lot specific to Mobile Banking.

Hope that helps-

Cheers!
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In life, there is a lot less that could get better and a lot more that could get worse.

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My views only!

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#1654013 - 01/20/12 10:17 PM Re: Mobile Banking AFaquir
Auditgirl50 Offline
Member
Joined: Feb 2009
Posts: 62
Texas
Thank you so much!!!

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#1654564 - 01/23/12 08:17 PM Re: Mobile Banking Auditgirl50
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,752
On the Net
Mobile Banking webinar this Wednesday.

http://calendar.bollearningconnect.com/main.php?view=event&eventid=1321642688450

The good news is there isn't a separate set of regs on mobile banking. The bad news is there isn't a separate set of regs on mobile banking. You adapt what we have and recognize there are limitations and questions that are not answered anywhere but in your desire to accept risk.
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AndyZ CRCM
My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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