02/21/2005
Are agreements to transfer interest paid on a certificate of deposit via the ACH to a customer's account at another financial institution covered under Reg E? If so, would the certificate then be subject to the periodic statement requirement?
11/15/2004
For security purposes what minimum requirements should be set to establish an Internet home banking account relationship over the Internet, i.e. should we require the individual to input their account number, Social Security Number, date of birth, mothers maiden name, or what other info at a minimum, to establish the account? Is there any regulatory guidance on this?
12/15/2003
I am trying to find out the format you recommend for us to save our Web site in before and after we make changes to it. Would you please advise the format?
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?
08/04/2003
As it relates to IT examinations, what are the top "hot buttons" for regulators?
07/21/2003
I've heard that IT examinations are much more rigorous these days. What are some general tips for surviving our next IT examination?
04/21/2003
As a financial institution looking for ways to better serve our customers, it occurred to me that it might be helpful to some of our customers who have questions relating to FDIC insurance to create a hyperlink from the bank's web site to the FDIC home page. Is there a potential problem in doing this without first obtaining FDIC, or other regulatory agency approval?
01/06/2003
Are there any requirements or criteria for Penetration testing? Can we perform the penetration testing ourselves? If we hire a third party vendor, should we require documentation saying they are authorized by the Regulators to perform the tests or that the testing will meet certain standards? Does the penetration testing requirement only apply to wired network or do we have to have penetration testing on the wireless as well?
08/12/2002
Currently, our ebanking customers must sign a printed online access agreement for ebanking service that we must keep in their file. If we were to make the ebanking agreement available online for the customer to view and select 'I agree' upon their initial logon to ebanking, would regulators still require us to keep a signed hard copy in the customer's file?
07/01/2002
Currently, our ebanking customers must sign a printed online access agreement for ebanking service that we must keep in their file. If we were to make the ebanking agreement available online for the customer to view and select 'I agree' upon their initial logon to ebanking, would regulators still require us to keep a signed hard copy in the customer's file?