We offer online banking that allows our customers to set up bill payments. We now offer mobile banking that allows acces to our onling banking product. If a customer uses their mobile phone to access their accounts online and authorizes a payment that has already been set up to be sent, is that considered a WEB entry under the new definitions? If so, what are our obligations for this type of service?

IMO this is still not a WEB...

As I understand it, online bill pay whether accessed by mobile device or otherwise is not a WEB because your customer (who would have to be the receiver in a WEB transaction) is initiating the transaction directly from their own account (which would in theory make them an originator of an ACH Credit, which by definition is also not a WEB) same as if they wrote a check...

If however your customer authorized the payment to say Chase... on Chase's website and not the bank's it would be a WEB origination... because then Chase would use this authorization to send an ACH Debit to your bank to withdraw the funds...

Cheers!