online wires

Posted By: ComplianceGrl15

online wires - 09/13/13 01:46 AM

is it ok to accept wires through our online banking? we have multiple (3) authentications.

what will this effect?

will we be required to give the esign notice?

what needs to be included in our terms and conditions?
Posted By: rlcarey

Re: online wires - 09/13/13 01:04 PM

Many banks utilize on-line wire systems. Unless you are dealing with the new international remittance transfer rules, I'm not sure what other notices would fall under E-Sign to process a wire transfer. As far as what needs to be included in your terms and conditions agreement for on-line wire transfers, that is really a question for your legal counsel. You need a binding agreement that specifically sets forth the commercially reasonable security procedures that will be in place.
Posted By: ComplianceGrl15

Re: online wires - 09/16/13 11:42 AM

We are not dealing with the new international remittance transfer rule (we are exempt).

So E-sign would apply?
Posted By: rlcarey

Re: online wires - 09/17/13 02:20 AM

E-Sign only applies to disclosures that have to be delivered in writing - so I am unsure of your question on how it relates to processing on-line wire transfer orders.
Posted By: ComplianceGrl15

Re: online wires - 09/17/13 01:32 PM

Okay, so since we don't have to give disclosures for a wire we don't have any e-sign requirements to follow through with??

We are a small bank that will not have to comply with any of the remittance rule.
Posted By: John Burnett

Re: online wires - 09/18/13 09:04 PM

That's correct, CG15. So if you handle one or two and decide to provide a receipt, for example, it won't have to conform to the regulation, and it can be electronic without worrying about e-SIGN.