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#613795 - 09/15/06 03:44 PM Procedures for signing up for online banking
ekbanker Offline
New Poster
Joined: Sep 2006
Posts: 6
Currently, we allow our customers to sign up for online banking through our site. Then, our reps review the request online, approve them and mail their password and ID separately via US Postal service. Is there anything as far as compliance goes that we have to have our customers physically sign before they sign up. They have to agree to the online disclosure before requesting an ID & password, but that's all we have them do right now? Are we missing anything here? Thanks in advance for any responses!!
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eBanking / Technology
#613796 - 09/15/06 04:17 PM Re: Procedures for signing up for online banking
Dazed and Confused Offline
Gold Star
Dazed and Confused
Joined: Feb 2006
Posts: 250
Big XII South
I do not believe any compliance issues exist with regard to your scenario. The decision to accept a customer's electronic signature vs. physical signature for on-line banking enrollment is up to the risk tolerance level of your bank. It sounds like your bank enrolls existing customers for on-line banking ... so you already went through the CIP steps.

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#613797 - 09/15/06 04:29 PM Re: Procedures for signing up for online banking
Spenser Offline
Member
Joined: Apr 2006
Posts: 52
Washington state
Do you allow new customers (no previous relationship) to open accounts online? How do they make their first deposit?

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#613798 - 09/15/06 06:04 PM Re: Procedures for signing up for online banking
ekbanker Offline
New Poster
Joined: Sep 2006
Posts: 6
Thanks for the response! We only allow existing customers to sign up, so I think that does get us past the CIP requirements as we're satisfying them when they come in to open the account. Thanks again!
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#613799 - 09/27/06 06:36 PM Re: Procedures for signing up for online banking
Titanic Offline
Gold Star
Titanic
Joined: Feb 2005
Posts: 300
My Workplace
Quote:

Currently, we allow our customers to sign up for online banking through our site. Then, our reps review the request online, approve them and mail their password and ID separately via US Postal service.




How are you able to prove that a customer accepted the online agreements?

Do you have reports or certificates via the online banking system?

Do you mail usernames and password to address on file?

Do you perform any sort of callback procedures to ensure that the actual customer received the username and password?

Your Online banking risk assessment needs to detail all the risks involved in offering such enrollment process and what controls you have in place to mitigate those risks..
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#613800 - 09/29/06 01:01 AM Re: Procedures for signing up for online banking
8675309 Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,115
Where the wind comes sweeping ...
EK - Our procedures are similar except the User ID and password are mailed together. The most important step--and maybe you are doing this--is to make sure the information is sent to the address of record on your core system. If someone enrolls online and provides an address that is different than where their statements are mailed, that is a red flag.

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#613801 - 09/29/06 02:07 AM Re: Procedures for signing up for online banking
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,971
Galveston, TX
Whoa - you're kidding right??? ID and password in the same communication. I would suggest you re-evaluate that process. One mailbox theft and you are in deep doo-doo.
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#613802 - 09/29/06 12:56 PM Re: Procedures for signing up for online banking
A_G Offline
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Joined: Jul 2004
Posts: 18,958
Quote:

Whoa - you're kidding right??? ID and password in the same communication. I would suggest you re-evaluate that process. One mailbox theft and you are in deep doo-doo.




Agreed. During my last internal audit of internet banking I realized that usernames and passwords were being mailed together in the same envelope. High priority finding that needed to be fixed ASAP. Now one employee mails the username and another employee mails the passwords with a lag time of a few days.
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#613803 - 10/04/06 02:37 PM Re: Procedures for signing up for online banking
ekbanker Offline
New Poster
Joined: Sep 2006
Posts: 6
Quote:

How are you able to prove that a customer accepted the online agreements?

Do you have reports or certificates via the online banking system?

Do you mail usernames and password to address on file?

Do you perform any sort of callback procedures to ensure that the actual customer received the username and password?

Your Online banking risk assessment needs to detail all the risks involved in offering such enrollment process and what controls you have in place to mitigate those risks..




Our system will not allow a user to continue with the online enrollment process unless they accept the online agreement. If they decline the agreement, the enrollment process is cancelled. We do mail our IDs and passwords to the address on file. Their enrollment information must also match what we have on file. If it does not, we do call. Other than that, we do not call the customer.
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#654539 - 12/19/06 11:52 PM Re: Procedures for signing up for online banking ekbanker
Harvey Offline
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Harvey
Joined: Feb 2001
Posts: 146
I would like to open this issue again. My bank is considering allowing existing customers to sign up for online banking using a quick enroll system. The customer would enter their social security number, account number, first name, last name, city, zip, DATE of BIRTH, and mother's maiden name. As long as the information the customer entered matches the information we have on record, our system would automatically allow the customer access to their account. Our system will allow the customer to enter the userID and password that they want, plus has a check box that says they agree to the terms and conditions of our online banking. I am concerned about customer verification for regulatory and safety and soundness. Does anyone else have a problem with this.

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#655334 - 12/21/06 12:59 PM Re: Procedures for signing up for online banking Harvey
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
We require customers to sign up for online banking in a branch office. It seems to me that the information you request can be easily obtained. Is that your concern?
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#655420 - 12/21/06 02:22 PM Re: Procedures for signing up for online banking Dolly Nugent
FraudHorn Offline
Member
FraudHorn
Joined: Dec 2005
Posts: 60
Maine
Having cusomers come into a branch is probably less risky than online enrollment. However, a fraudster could probably find a way to pull that off too if they were ambitious enough. Online enrollment is a convenience to customers. As long as the bank has included the process in a risk assessment, included sufficient controls to mitigate the risk, I doubt your regulators will have a problem with the online enrollments described in this thread. Except the part about mailing user IDs and passwords together, that's a no no.
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