When a customer transfers money between two accounts at our bank via their home computer using our bank's internet web site, are these transactions covered under Reg E?
If a transfer is conducted through on-line banking product, do the periodic statement requirements <a href="http://www.bankersonline.com/regs/205/205-9.html">(205.9)</a> of Reg E apply?
We currently offer internet banking to include the ability of transfering between accounts. We have received many requests to allow for transfers between business and personal accounts via internet banking. What potential risks are we taking to allow these interactions?
We have recently introduced internet banking to our customers. We have had a multitude of requests to allow transfers between business and personal accounts. What are the potential ramifications of this and what IRS rule addresses this issue?
We like to keep on top of the latest potential problems with Internet banking so we can learn from the mistakes of others and protect ourselves against make the same mistakes. Heard about any new ones lately?
We have a message posted on our Web site that tells customers not to submit emails that contain sensitive or confidential information and that tells them not to use email for specific transaction-related requests. Our system gives us the capability of doing auto-responders to any email submitted. We have drafted an auto-responder that thanks the sender for their message, acknowledges that it was received, but basically reiterates our policy about how they shouldn't be sending confidential or sensitive information or anything about a specific transaction or account. It has been suggested that we might want to add something to it to say something like "We will not act upon email requests for funds transfers, stop payments, account closings, or fraud notifications. These must be done either in person, or by calling such and such number." I'd like to know whether you think this is a good approach or whether there's a better way to handle this. We almost considered not even posting an email address on our site at all to just stop the email.
Can you briefly tell me all the regulations involved with ACH transactions?
We have an elderly customer who has a caregiver. One of the duties of the caregiver is to help the customer write checks for monthly bills. Recently, we've been concerned that the caregiver is perhaps helping herself, rather than helping the customer, because some of the checks are larger than normal and others are made out to payees that would be unusual for our depositor. We've tried talking with the customer, because we're alarmed at her rapidly decreasing balance, but she does not appear to be able or willing to stop the misuse of her funds. The customer has signed each item, but we still feel awful paying them because we believe she's being taken advantage of.The customer's grown children live out of state. We're tempted to call one of them to discuss the situation, but we can't do so because of financial privacy constraints. Any other suggestions?
We will be launching online banking in about 60 days. I would appreciate any ideas you might have for making our customers aware of it, promoting it outside the bank, getting people to try it.
by Barbara E. Hurst, Editor
It's the beginning of a brand new year and I'm going to take time out to pat a few of you on the back.
Here's a toast to: