Can we state this on our Reg E disclosure? I don't think so but wanted to bounce it off you:"The use of web enabled phones (smart phones) for access to Internet Banking is currently not a product offering. ABC Bank shall not incur any type of liability related to the use of web enabled cell phones for accessing Internet Banking."
We are deciding whether or not to provide e-statements on our internet site. What are the required disclosures needed to provide this service? I understand that the customer can choose whether or not to receive his/her statement electronically.
Our internet banking crew wants to allow on-line accounts to be opened without requiring the signature card. At this time, we have been sending the account documents to the customers and requiring them to send back a signed card. I'm not comfortable with this concept without having an agreement with a customer we have never seen.
We are in the process of starting e-statements for our customers. They will have to sign into our secure internet banking site to view their statements. However, the statements will be coming from another imaging company that does our imaging processing. These two companies are forming a single sign in for the images. I keep hearing about "demonstrable consent"; would we still have to prove this with our customers signing into a site that they have been or does this rule apply because it is the customers' actual statements being viewed?
I am wondering if there are any specific regulations or guidelines pertaining to mobile banking. We are going to add a function onto our internet banking website that allows customers to choose an option to access their account(s) from their mobile devices. I would just like to know if we need to consider other compliance issues separate from internet banking.
We have a form available for customers to sign, who have access to Internet banking and online statements, if they wish to discontinue receiving paper statements in the mail. Is it necessary to have signatures of all signers, if it is a joint account? Can one account owner opt out of paper statements for a joint account?
When a business customer wants to view his accounts online and also make transfers, is there an agreement that needs to be signed stating which of his employees can have access to this capability? We do not know who of that business is making a transfer or inquiry, therefore we cannot monitor that activity. I would think that the bank is not liable and has no control. Is this correct?
How can we identify an ACH transaction as internet gambling when the transaction will probably have an SEC code of WEB? What is everyone doing to try to monitor for internet gambling transactions?
Are we required to have lobby notices of the Unlawful Internet Gambling Act, effective 12/1/2009?
Management is searching for a way to use the internet sign-in process by customers (two factor authentication) as "demonstrable consent" for purposes of E-Sign. I am seeking support for why multi-factor alone cannot be used as demonstrable consent, verifying that the customer was able to receive and read materials sent to them.