08/14/2006
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?
08/14/2006
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?
07/24/2006
In providing the HELOC early disclosures with an Internet application, is it acceptable to provide the disclosures via a link (before the applicant gets to the application) which link the applicant can bypass?
06/19/2006
We are converting to a new internet banking program and would like to offer customers a function that would allow them to place a stop payment online. We will have "real time" capabilities so the stop would go on to the Core system. My question is this, an oral stop payment is only good for 14 days and requires a customer's signature on a stop payment request to maintain the stop for 6 months. How are stop payments which are entered by customers themselves on the internet to be treated? Does the fact that the customer signed on to the secure site and performed this function themselves suffice, or do we need to send out and obtain a customer's signature on a "paper" stop payment order?
05/15/2006
How are transactions from internet banking sites viewed when a money market account is involved? The Reg does not address transfers via internet sites. Are these considered the same as telephone withdrawals?
05/15/2006
We are considering making loans via the internet. I know CIP and internet security need to be arduous. What other considerations and compliance issues are there?
04/24/2006
Do internet transfers initiated by our customer qualify as transactions included in the limited number of withdrawals on Reg D accounts?
03/20/2006
My bank currently assists several officers in synchronizing Palm type devices and laptops with their desktop PCs. We do not have a policy for this and wonder now what requirements should be in place?
02/27/2006
We are considering offering bill payment on our internet banking website. What regulations are applicable, and are there any additional disclosures required?
02/20/2006
We are considering e-statements. Is there a regulation that requires a customer to receive a statement or notice by mail periodically? My concern is the loss of contact. The customer might obtain statements on the internet, but we might not know the physical location of the customer.