A customer realizes that his/her debit card or PIN is lost or stolen, but they do not report it to the bank. Who is liable?
I have a question regarding the article <a href="http://www.bankersonline.com/technology/gurus_tech102003b.html">Test Drive Procedure on E-Statements</a>. The article indicates that we must send the customer a sample record/document using the same electronic method proposed to use for the disclosure/statement you wish to employ. The article further states that we must include within that record a piece of information that the consumer is unlikely to know without reading the record. We then must require the consumer to communicate that piece of information to you or your system. Receipt of the correct "key" from the consumer provides evidence the consumer has equipment to receive and display the record and the consumer can read it. Of course, this is in addition to the consumer's affirmative statement that he wishes to participate and all that other stuff that has to happen. We are in the process of implementing e-statements and our proposed process is this: Electronic statements and optical check images are already available to members logged in to our Web site, along with paper copies that continue to be mailed to the customer. However, if the customer wants to receive notice when their e-statement is ready for viewing (pull system versus a push system), they will click a button indicating that they want such notification. A disclosure containing all term and conditions will pop up at that point and the member will have to agree to. At that point, an email will be generated to the email address on file and paper statements will no longer be generated. The notification email will contain a hyperlink that when clicked, will take the customer to their e-statement where they'll be required to logon before reviewing the statement. Does this process, in your opinion, meet the requirements listed above? To my knowledge, there are no plans for anyone in our institution to ensure that the member either received the notification or was able to view the statement.
Our bank is getting ready to change from ATM cards to VISA check cards and are working on disclosures/apps. We were told that under Reg E error resolution, POS transactions now only have 10 days instead of 20 along with foreign transactions and new accts. Is this correct? When did it change? We have lots of statements with 20 days on them, is that a major problem?
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"?
As it relates to IT examinations, what are the top "hot buttons" for regulators?
We are new to internet banking. We have our customer statements as part of our online product. The statement has a complete copy of our mailed version. We have customers asking us to stop their paper copy. What are the rules and to start this what would need to do.
We post periodic statements on our web site instead of emailing them. Do we have to email customers each time the statements are posted and tell them they have been posted? If they have more than one account with us do we have to send multiple emails?
What are the regulations in regards to offering an electronic savings account? We would like to offer one that limits the deposits to electronic only and encourages ATM withdrawals, We would target customers with electronic Social Security or SSI payments into their accounts.
We are starting the process for providing our internet banking customers their checking account statement electronically. We currently provide an abbreviated Reg E disclosure on the back of each monthly statement. In an electronic environment how would you suggest we accomplish this?
In an article titled "Longevity of Online Statements" by Andy Zavoina, Andy discusses the length of time transactional information should remain available to the Online Customer. Does this period of time also apply to Commercial Online Access Customers? If so, can the bank still make the information available for less than that time frame (Say 45 days)?