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#610181 - 09/07/06 04:49 PM Internet Banking Audit Program (BOL)???
Tennismom Offline
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Tennismom
Joined: Jan 2004
Posts: 778
On the BOL Internet Banking Audit Program under Accounting and Processing Step #16 b) - "...Determine if the documents (contract/agreement) address the bank's authority to monitor, store, and retrieve electronic transmissions...between bank and its customer."

There is a reference that this is applicable to FDIC regulated banks. I have been unable to find this in any FDIC guidance.

Can anyone tell me if this statement is or is not a requirement of the FDIC? If it is a requirement, where I can the citation.

Thanks.

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eBanking / Technology
#610182 - 09/07/06 05:21 PM Re: Internet Banking Audit Program (BOL)???
Dazed and Confused Offline
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Dazed and Confused
Joined: Feb 2006
Posts: 250
Big XII South
It's included as a "best practice" in the FFIEC E-Banking booklet ... so is it possible that the reference in the audit program should be FFIEC instead of FDIC?

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#610183 - 09/07/06 05:46 PM Re: Internet Banking Audit Program (BOL)???
Tennismom Offline
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Tennismom
Joined: Jan 2004
Posts: 778
Thanks Dazed and Confused!!!!

I looked through the FFIEC E-Banking Booklet (August 2003)but could not locate. Do you have a page number?

Do you have that verbiage in your agreements?

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#610184 - 09/07/06 06:15 PM Re: Internet Banking Audit Program (BOL)???
Dazed and Confused Offline
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Dazed and Confused
Joined: Feb 2006
Posts: 250
Big XII South
Refer to the following in the E-Banking Booklet ...

1. First bullet on p.9
2. Customer agreement section on p.D-5
3. Legal and compliance issues on p.37-39 (disclose the bank's security policies to the customer - e.g., monitor, store and retrieve activity b/w the bank and customer)

If you want to see example wording ... go to a bank's website and review their on-line banking agreement. The wording is normally included in a section titled "security" or something similar.

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