Has anyone rolled out the Apple Pay or Android Pay services? If so, what sort of changes, if any, did you make to your account Terms and Agreements and Online Banking Agreement or Mobile Banking Terms and Conditions? I have the Terms and Conditions for the Mobile Wallet and we're adding that to the Mobile T&C. I just think there should be information in our other agreements, but can't get any support from the vendors. I have never worked on a project where the vendor didn't have example documents that we could build off of. We create our own disclosures and have the banks attorney approve or make changes for us. I would appreciate seeing what others have done.

A Google search on "Apple Pay Terms and Conditions" yields several results.

What should be included on the risk assessment for digital wallet? Can it be included with the debit cards?

We didn't add anything to our account terms and conditions. Being that it is a stand alone product, we kept it's T&C's separate. We also spoke with our disclosure vendor who told us it's not yet regulated and therefore they do not have any thing to offer us. We searched other banks for idea's and ultimately tasked our compliance team with writing their own T&C's for the product.

ultimately tasked our compliance team with writing their own T&C's for the product.

Seems to me that would be best handled by legal counsel and not a compliance team.

We decided to reach out to our attorneys. I can find T&C's for the app, but nothing other than P2P language for the banks account Terms and Agreements. I'm not a lawyer, I don't write contracts.