Has anyone else had to provide their regulatory agency information before starting something like this?

We have been in contact with our servicer (Fiserv), and they have told us that there is information they can provide us to give to the FDIC, such as a security overview, certification report and SAS 70.

This is all new to us, so do we simply call the FDIC and tell them we’re going to start this and then next time we are examined, give them what they ask for?

Or, do we need their approval to do this? It’s not like we’re opening a new branch.

Thanks

I am with an OTS bank and we did have to notify them before changing our site to transactional. They then sent us a questionnaire which dealt with how the transactions would be processed, what security we had and they requested a copy of our web banking policy.

They're probably referring to your notification obligation under the Bank Service Company Act, outlined in FIL 49-99.

Thank you Walleye Woman and Bartman, I appreciate your help.

What do you mean by 'transactional?' If you are simply going to offer internet banking through Fiserv, that's not considered transactional - at least by insurance companies, e.g. no 'outside' payments - only portfolio transfers involving common ownership. Of course, bill payment changes that scenario.

You may already know, but you need an Internet Banking Policy in place and insurance coverage as internet banking is subject to separate coverage and expense.

You do need to contact your primary regulator as part of implementing this product.