Answer:
Online banking agreements, like any contract, should be drafted by bank counsel. If you are using canned documents from a vendor, then bank counsel should review and approve them. Equally important, affected business and servicing managers must review and approve the substance of the agreements; legalese doesn't matter if you don't do what the agreements say. No regulatory disclosures apply uniquely to internet banking. In order to determine any additional disclosure obligations, examine what services "internet banking" includes and follow the rules that apply to that service. For example, if you will provide online payments then you may have a new access device that will trigger supplemental Reg. E disclosures.
First published on BankersOnline.com 7/30/07
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