Skip to content
BOL Conferences
Thread Options
#2241241 - 08/19/20 02:03 PM Online Banking Agreement Content
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 540
From a compliance standpoint, what items should be included in a bank's Online Banking Agreement?

Return to Top
eBanking / Technology
#2241244 - 08/19/20 02:18 PM Re: Online Banking Agreement Content TeamComply
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2241284 - 08/19/20 07:23 PM Re: Online Banking Agreement Content rlcarey
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 540
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?

Return to Top
#2241292 - 08/19/20 08:06 PM Re: Online Banking Agreement Content TeamComply
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
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.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top

Moderator:  Andy_Z