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#2241241 - 08/19/20 02:03 PM Online Banking Agreement Content
TeamComply Offline
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From a compliance standpoint, what items should be included in a bank's Online Banking Agreement?

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eBanking / Technology
#2241244 - 08/19/20 02:18 PM Re: Online Banking Agreement Content [Re: TeamComply]
rlcarey Offline
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rlcarey
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Galveston, TX
I am not sure there are any compliance issues unless you are talking about specific fees not previously disclosed under TISA or changing your Reg E disclosure.
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#2241284 - 08/19/20 07:23 PM Re: Online Banking Agreement Content [Re: rlcarey]
TeamComply Offline
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So really such agreements typically focus on the contractual obligation/rights of the user and of the Bank?

And as far as our Reg. E disclosure goes, it does include information on services provided through use of internet and mobile banking services. Is there something additional I need to consider with regard to our Reg. E disclosure?

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#2241292 - 08/19/20 08:06 PM Re: Online Banking Agreement Content [Re: TeamComply]
Andy_Z Offline
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Andy_Z
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On the Net
Reg E should be a disclosure in itself. I'd prefer not to splinter it in different areas as that makes maintenance and updates harder.

A separate online agreement may include E-SIGN as that is related, it would require address updates for email, it may require the user not block pop-ups if you use them, that they display your website as it is written so that they see what you intended, that they not share logon credentials and that each account owner or authorized user have their own credentials. The user shouldn't shrink the page making disclosures hard to read or distorting them. Some of these may also impact ADA protections. These are not issues you'd likely "enforce" but if there is a dispute later and in court and the person displays a screen capture of your site, are they showing it as it was intended to be seen, or if there is a dispute over a transaction, it is helpful for the bank to know who logged on to do it.
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