12/11/2006
Are Internet Banking and VRU transactions considered EFTs requiring a periodic statement to be sent to a customer each month in which one occurs?
11/27/2006
Is a business account covered by regulation E? If they enter their account numbers on the internet and it is somehow compromised is the bank liable for the transactions?
10/09/2006
We are finally developing a bank website and will have online application forms. What are the compliance requirements for submitting an online application? We are in need of some good resources for internet banking compliance in general, what resources would BOL recommend?
10/09/2006
We have a few customers that signed up for internet banking but haven’t used the services for over a year. We would like to deactivate their Online Banking accounts. Are there any regulatory requirements that we must follow prior to deactivating these online accounts, including customer notice?
10/02/2006
We feel that our network is very secure against attacks that originate on the Internet. Are there other areas about which we should be concerned?
10/02/2006
In the past, we sent mortgage loan closing documents to the title company via the internet. We stopped this practice because we feel that without having a secured e-mail line, and without encrypting the data, we would be in violation of GLB. Same with sending our Good Faith Estimates, or other disclosures. We stopped sending via e-mail to customers because of GLB issues. Are we correct in that it would be a violation of GLB to send non-public financial information electronically over a non-secure line?
10/01/2006
Does anyone have some sample policies and procedures regarding Incident Response relating to Internet and/or Technology or any suggestions as to what points should be included?
09/25/2006
Do you have anything that would address the issues outlined in the OCC 2005-35 Bulletin concerning Authentication in an Internet Banking Environment such as any type of policies and/or checklists?
09/04/2006
Would we meet the multifactor authentication requirements by adding a second password requirement to the logon page of internet banking?
08/28/2006
If we post our Do Not Call policy on our website does this satisfy the 'available upon demand' requirement?