For security purposes what minimum requirements should be set to establish an Internet home banking account relationship over the Internet, i.e. should we require the individual to input their account number, Social Security Number, date of birth, mothers maiden name, or what other info at a minimum, to establish the account? Is there any regulatory guidance on this?
I am currently printing verbiage on the face of checks that I write specifically stating that the payee is NOT authorized to initiate an EFT for payment of a check and the check may not be electronically converted. I am also stating on the face of the check, under the check number, that the serial number is not valid for electronic check conversion. After studying 12 CFR 205 (FRB Regulation E) it seems as though this is the my only chance as a consumer to prevent this practice. What is your opinion? Is the front or back of a check the correct place to put any authorization or conditional information?
Printing Mailing Bar Codes on Your Envelopes
by Jim Calloway, Director Oklahoma Bar Association Management Assistance Program
High Outbreak of New Mass Mailing Worm
We are a small three branch bank. Our CEO is pressuring the staff to open new checking/savings accounts online at our website. I have been to numerous banking seminars, and from what I understand, banks that currently are opening up new accounts on their websites are suffering substantial losses. What can we do to prevent this from happening at our institution in the event we decide to open new accounts on the Web? And can we restrict the opening of new accounts to residents of our state only?
Our bank wants to offer loan applications online. The customer can print the application, then submit it in person or mail the application. The customer cannot enter any information online. This application cannot be submitted via the Internet. My question is, we are offering the application in PDF format, which would require the user to download and install the Adobe Acrobat Reader. Is the bank responsible to disclose anything about Acrobat or the link to the Adobe site?
What do you think should be the driving factors behind a decision to move to E-Statements for our customers? Is there a downside? Are most banks using them in addition to, or instead of, paper statements? Do you need to do both for a while to make customers more comfortable?
Email Retention. Is there any print out documentation that shows or explains how long should emails be saved? We have changed our email policy twice and our retention level is currently 60 days. If we have a legal problem can we be in trouble?
Once a customer has gone through the eSign Process (e.g. consented to go paperless so as to receive their monthly DDA Statement electronically) can they then change status at a Banking Center? Can they go into a Branch and have Relationship Manager make a change; e.g. turn the paper back on, a few months later turn it back off, etc? Or, as is the case with the initial consent, do they have to make any changes themselves rather than having someone at a Branch do them?
The term "e-banking" is what I need help with. What is the definition of "e-banking"? Our bank offers on-line banking, however, accounts cannot be opened on line, only transactions. The paperwork is done either in-person or by mail. Is this true "e-banking"?