Answer:
No, when a customer transfers funds between accounts that they own it is not automatically considered a high-risk transaction. The two elements that make a transaction high-risk are: 1) a transaction that provides access to non-public personal information, which may be used to facilitate identity theft, and 2) movement of funds to other parties, which includes bill payment and the ability to transfer funds to other people within or without the institution. Although the answer is no, you will have to look carefully at the screens displayed to see if there are other factors that may