07/28/2008
Is there any regulation that requires internet banking passwords to expire? On that same note, are there any regulations that require internet banking passwords to contain alpha and numeric characters?
06/16/2008
I was wondering if anyone can shed some light on the internet gambling bill. I know that it was part of the Safe Port Act and comments were due by December 12, 2007. Have any final regulations been posted? Where do we stand from a compliance standpoint?
06/16/2008
With regard to Esign, can the pre-consent disclosure itself be used to satisfy the demonstration requirement? Our plan: the only way to sign up for e-statements would be to log on to our Internet Banking system, navigate to the statement page, and open the pdf disclosure/sign up form. This is the same format and location in which the statements will be delivered. My thinking is that if this is the only way to obtain the sign up form, the customer has clearly demonstrated their ability to access the statements. Upon receipt of the sign-up form, we would send an email to the address on file, which would require a reply from the customer in order to also demonstrate their ability to receive the Alert messages. E-statements would only be activated after all of the above.
06/09/2008
We had a customer call in to the bank because she had a transaction that was being denied. She was trying to place an order for a camera over the internet. It turns out that she was over her limit for the day. I reset the limit so her transaction would go through and then she placed her order. Within 30 minutes she called back and spoke to one of our call center reps stating that the company had preauthorized more than she had authorized and she wanted to do a dispute for fraud. In her phone call with the call center she had mentioned that the company was cancelling her order and was going to credit her account. What should be done in a situation like this? The customer is claiming Visa Zero Liability stating that under it she can dispute a charge for any purpose. Our ATM department has had some training on Reg E, but we are still confused as to when Visa rules come into play and what exactly Visa considers unauthorized charges. The customer gave her information to this company so she authorized them to use it, but they took more than they were authorized., so shouldn't this be between the customer and the merchant?
05/26/2008
We have a customer that used his debit card to make a purchase on the internet. He says he did not receive the product and was charged more than what the website said he would be charged. He contacted the merchant and they said they would send him another product. He says that he has not received that product either. Can he dispute this through the bank? If he can, is he covered under Reg E or Visa?
05/05/2008
When we open new accounts, we like having customers sign up for online banking at that time. Marketing created a form where the customer waives the requirements for demonstrable consent and certifies they meet the hardware and software requirements we have to get our e-statements. Is this satisfactory?
05/05/2008
What regulation covers internet banking bill pay?
03/24/2008
We have an officer that is wanting to do away with email and internet because she is afraid of a virus shutting down our system. We have proper firewalls/virus programs etc. How can I explain to her that our virus programs are designed to keep this from happening? She is wanting me to tell her with 100% certainty that nothing will hurt our system. I feel comfortable with the protection that we have however, I cannot guarantee that nothing will happen.
02/11/2008
We are in the process of converting to a self enrollment process for online banking. If our customer clicks "I agree" to accept the agreement and the wording to allow transfers is included in that agreement, do we need to send them a separate form which includes their signature for the transfer authorizations?
02/04/2008
Are there restrictions on opening accounts on the internet for residents of states where the state chartered bank has no branches?