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#2181274 - 06/11/18 05:12 PM Wire Call Back Authorization
kjbabington Offline
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Posts: 194
FL
When completing the wire authorization form would it be acceptable for a business owner to list a person to authorize a wire or be a call back contact if that person is not an authorized signer on the account?

I am more comfortable with the person possibly being a call back person, but not actually authorizing the wire, since they are not on the account, however if the customer grants them the authority on the wire authorization form does that protect the bank from risk?

Thanks

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Operations Compliance
#2181276 - 06/11/18 05:17 PM Re: Wire Call Back Authorization kjbabington
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,282
Illinois
Quote:
would it be acceptable


Only if your bank is willing to accept the financial/legal risk of the business owner later claiming fraud. Call backs are a dangerous proposition even when an authorized signer is involved. The bad guys are hacking phone lines and emails, sending fraudulent wire requests and the bank ends up talking to the bad guys because the customer number is forwarded without their knowledge.

Operationally, I wouldn't go near this, but the person the bank should be talking to is its legal counsel that would draw up such an agreement.
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#2181280 - 06/11/18 05:32 PM Re: Wire Call Back Authorization kjbabington
kjbabington Offline
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Joined: Jan 2006
Posts: 194
FL
Thanks!

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#2181338 - 06/11/18 10:44 PM Re: Wire Call Back Authorization kjbabington
HappyGilmore Offline
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Pulling people out of the ditc...
our wire agreement with our customers allows a customer to designate someone that can either originate or approve wires (just can't approve one they originated). Does not require them to be an authorized signer on an account, and has specific actions they must follow be it via our cash management system for online origination, or user ID/PIN (with other controls that go unnamed here) for voice origination. we will only call back to a phone number listed in the wire agreement.

where we have run into issues is that someone that can originate a wire goes into a branch and the branch lets them transact business other than wires where they are not a signer
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#2181370 - 06/12/18 01:33 PM Re: Wire Call Back Authorization kjbabington
Dog Lady Offline
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Joined: Dec 2015
Posts: 74
We have very high wire volume for our size.

Our controls are similar to Happy's. Our agreement allows anyone to be authorized to transact wires as long as they are on the wire agreement (with specific capabailities listed - maximum amount, repetitive only or free form, origination and/or call back, dual control, etc). The wire agreement also lists email addresses and direct phone numbers for each of these individuals, which allows wire staff to identify whether emails received are at least from a valid address (still not indiciating validity of the request of course). The phone number on the agreement or in the core system is the only number used to call them. The wire agreement must be executed by an authorized signer on the account, and their written consent is required to add users or change capabilities of existing users authorized to transact wires. We have passphrases set up by the users to identify them whether they call in or we originate call back.

Unlike Happy, we have not had an issue with allowing those individuals to transaction branch business. Authorized signers are listed as such on our core system. People only authorized to transact wires are not. Wire information (authorized transactors and passphrases) is stored on a separate system that is only accessible by operational staff (not the front line).

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#2181374 - 06/12/18 01:42 PM Re: Wire Call Back Authorization kjbabington
rlcarey Offline
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Galveston, TX
"The wire agreement must be executed by an authorized signer on the account, and their written consent is required to add users or change capabilities of existing users authorized to transact wires."

This is the only hole I see in this process. An authorized signer on an account does not have the authority to grant permission to other individuals to conduct transactions on behalf of the entity. This can only be supported through a proper resolution by the governing body of the entity.
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#2181377 - 06/12/18 01:49 PM Re: Wire Call Back Authorization kjbabington
Dog Lady Offline
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Joined: Dec 2015
Posts: 74
rclarey, thanks for the clarification. When I said authorized signer, I meant someone authorized by the resolution.

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#2181394 - 06/12/18 02:33 PM Re: Wire Call Back Authorization kjbabington
BrianC Online
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BrianC
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Illinois
To Randy’s point, the resolution may provide signing authority, but that does not mean it grants authority to authorize other individuals to act on the business’ behalf.
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#2181473 - 06/12/18 07:06 PM Re: Wire Call Back Authorization kjbabington
HappyGilmore Offline
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Pulling people out of the ditc...
we require a resolution which details who can add/delete/modify users. our core system also does not list those authorized for wires but does contain a section that directs users to look to the wire agreements for proper authorization
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