05/02/2005
We are looking to implement email notification of receipt of deposit instead of mailing paper back. I have seen comments on e-statements and E-sign and disclosure requirements but don't think any of that applies to receipts. Can you refer me to the regulation that states we are required to provide a receipt and the corresponding rules?
01/31/2005
I've read your articles on Reg. E Disclousres on the Web. But we are taking applications for Internet banking via the Web. Do we still need a Reg. E Disclosure and what should we be sure to include and watch for?
01/17/2005
I am in the process of developing policies and procedures for Online Banking. I'd like to ensure that we encompass all key areas. Do you have any templates that you would be willing to share or sites that I may review to extract info?
11/15/2004
Currently, the bank I work for, [removed for purposes of confidentiality], does not mail a hard copy Online Banking Agreement and Disclosure when a customer signs up for online banking. We have an online disclosure that says to read before filling out and mailing in the online banking application. There is not an "I agree" or "I accept" button on the web site and customers must mail the application to us. Do we need to mail a hard copy agreement and disclosure?
03/01/2004
We do not open accounts online. The Reg E disclosure on our Bank's Web site covers the types of transfers that are allowed for Online Banking along with fees, documentation, Financial Institution's Liability, Confidentiality, Unauthorized Transfers, Error Resolution Notice, etc. (i.e., things we don't need), but this disclosure does not include other EFTs, such as check conversion. Is it required here? The Reg E disclosures provided to customers other than on the Web (new account, debit card application, etc.) do include that type of EFTs.
02/02/2004
Can a customer waive his Reg E rights? We have customers who do not want to receive a monthly statement, even though they have electronic transactions that are subject to Reg E. The customer is able to view their account history via our Online Banking product. Must we send them a paper statement?
11/03/2003
We will be providing online banking to our customers and I would like some clarification on the modifications of our current policies and what policies should I create from scratch. I will edit our Privacy Policy to reflect a new online privacy policy. I will also edit our CRA file, edit EFT disclosure, edit IT policy and evaluate our risk assessment plan. I will CREATE an online banking policy, online banking agreement, firewall policy and an internal audit checklist. Does this sound like I am moving in the right direction? Any additional items I should address?
11/03/2003
If a customer performs transfers between his MMDA and his checking accounts using the bank's "on-line banking" product and exceeds the preauthorized limit of 6 transactions, would he be considered in violation of the reg? I would think that because he is performing the transaction himself, it would not exceed the limit (similar to using an ATM card at an ATM machine). Have you heard anything from the regulators about this?
10/20/2003
With respect to Reg E disclosures, we will be offering online banking to our customers soon and I need to know if we need to re-disclose. (The service will be free of charge and our system will not offer bill pay. We will not open accounts online that will still be done in person. We will just be the account holding institution.) But, if I understand this correctly, we should edit our REG E disclosure to show this as a service we offer. Correct?
08/18/2003
The term "e-banking" is what I need help with. What is the definition of "e-banking"? Our bank offers on-line banking, however, accounts cannot be opened on line, only transactions. The paperwork is done either in-person or by mail. Is this true "e-banking"?