I know there have been lawsuits against banks due to fraud involving unauthorized ACH debits on business accounts. What is the status of those suits?
Is the Bank required to have a special procedure section on the DATA form? Should we give the client the option to decline the use of the security procedures that are offered by the bank?
Regarding automated telephone banking systems, customers can currently inquire (get account balance and info) by phone with their account number and last four digits of their SSN. If they want to transfer funds between their accounts, they must complete an application. My bank wants to give automatic access to transfers too. I'm concerned about Reg E issuing access device rules. Is calling the number and following the steps, "requesting" the access? We have new operations personnel who say all banks do this automatically. Other banks don't have customers fill out a form or call and talk to someone, it is all done through the automated phone system. Does this comply?
Will having the customer log on to internet banking suffice for their digital signature if we want to change the terms of an electronic agreement or make some other product or service available?
How do you recommend that a Remote Deposit Capture customer secure its scanner? Is the scanner itself a security risk?