01/02/2007
Our e-newsletter program is brand new to us. If we provide a link to an external site that is not co-branded with our bank, are we required to have a speed bump? If so, what is the bare minimum we need to say? The reason I am asking is that we have a speed bump in place on our web site and it is quite lengthy. In this instance, if I were to add the speed bump, it actually has more content in it than our e-newsletter. I do receive e-newsletters from other banks and they do not have speed bumps. Since this area is new to us, I want to have policies in effect as we go forward.
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?
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?
12/01/2005
The U.S. State Department issued a final rule in October that creates the requirement that new U.S. passports contain a radio frequency computer chip to affirm identity of the document holder.
07/01/2005
While information technology is not usually the responsibility of the compliance manager, there are certain IT functions that the compliance manager should make sure are in place.
11/01/2004
Although no state has yet succeeded in creating a driver's license beyond the traditional plastic tool, efforts are underway on several levels to move into "smart licenses" - licenses that contain
09/06/2004
We occasionally receive telephone inquiries to verify that a customer account number is active/correct, because the customer signed up for an electronic payment. Our privacy policy requires that we obtain a written authorization from the customer to release information. Is verifying an account number given to us considered releasing information? We are trying to obtain authorization from the customer before verifying an account number.
03/01/2004
Question: We know that records must be maintained for our Customer Identification Program. We are debating how to do this. Do you have any advice?
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?
08/18/2003
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?