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#1851768 - 09/13/13 01:46 AM online wires
ComplianceGrl15 Offline
Gold Star
Joined: Apr 2011
Posts: 257
West Virginia
is it ok to accept wires through our online banking? we have multiple (3) authentications.

what will this effect?

will we be required to give the esign notice?

what needs to be included in our terms and conditions?

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eBanking / Technology
#1851791 - 09/13/13 01:04 PM Re: online wires ComplianceGrl15
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,294
Galveston, TX
Many banks utilize on-line wire systems. Unless you are dealing with the new international remittance transfer rules, I'm not sure what other notices would fall under E-Sign to process a wire transfer. As far as what needs to be included in your terms and conditions agreement for on-line wire transfers, that is really a question for your legal counsel. You need a binding agreement that specifically sets forth the commercially reasonable security procedures that will be in place.
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#1852238 - 09/16/13 11:42 AM Re: online wires ComplianceGrl15
ComplianceGrl15 Offline
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Joined: Apr 2011
Posts: 257
West Virginia
We are not dealing with the new international remittance transfer rule (we are exempt).

So E-sign would apply?

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#1852700 - 09/17/13 02:20 AM Re: online wires ComplianceGrl15
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,294
Galveston, TX
E-Sign only applies to disclosures that have to be delivered in writing - so I am unsure of your question on how it relates to processing on-line wire transfer orders.
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#1852747 - 09/17/13 01:32 PM Re: online wires ComplianceGrl15
ComplianceGrl15 Offline
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Joined: Apr 2011
Posts: 257
West Virginia
Okay, so since we don't have to give disclosures for a wire we don't have any e-sign requirements to follow through with??

We are a small bank that will not have to comply with any of the remittance rule.

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#1853557 - 09/18/13 09:04 PM Re: online wires ComplianceGrl15
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
That's correct, CG15. So if you handle one or two and decide to provide a receipt, for example, it won't have to conform to the regulation, and it can be electronic without worrying about e-SIGN.
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