Topic: Online Banking
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If we send an electronic account statement to a customer, but the email notification bounces as undeliverable, are we required to switch the customer back to paper statements?
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We are not aware of any law or rule that would explicitly require you to switch customers to paper statements in this situation. However, it may be prudent to do so. Assuming that the customer has agreed to receive statements electronically (as required by the federal Electronic Signatures in Global and National Commerce (ESIGN) Act…
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Can we allow clients to request stop payments through an online system or do we need to obtain a hard copy of the form?
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Disclaimer: The Electronic Commerce Security Act (ECSA) was repealed and replaced with the Uniform Electronic Transaction Act (UETA), effective June 25, 2021. Please note that this change may affect the continued accuracy of this guidance as it pertains to the ECSA. We do not believe that your organization needs hard copies of stop payment orders…
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We are implementing a new online loan application system. When we send a confirmation email to online applicants, do we have to send that through a secure email program?
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We believe that the automatic email sent to online loan applicants should be sent through the bank’s secure, encrypted email system. In our view, the emails would contain enough information about the customer to justify the added protection; even the fact that someone applied for a loan for the bank would be considered “personally identifiable…
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We are launching e-statements. How specific do the disclosures have to be as far as hardware and software requirements? Our disclosures state that customers should have internet access, and e-mail account, and Adobe Reader for reading .pdf documents.
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We believe that a few additional items would have to be added to the Electronic Statement disclosures. The federal Electronic Signatures in Global and National Commerce (ESIGN) Act and the Illinois Financial Institutions Electronic Documents and Digital Signature Act require the following items of information in electronic statement disclosures (15 USC 7001(c)(1)
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Our website has a privacy policy, but the mortgage area of our website is run by a third party vendor. Should our privacy policy also appear on the third party’s website?
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First, we must clarify that there are two types of “privacy policies”: The initial and annual notices of your privacy policy required by the federal privacy regulations (under the Gramm-Leach-Bliley Act), which applies to all uses of nonpublic personal information (the “GLBA privacy notice”) A website privacy notice, which applies only to the use of…
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Can we allow trust accounts to use online billpay?
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If the customer has the authority under the trust agreement to use the trust funds for any purpose, we do not see any problem in allowing the customer to use an online bill pay account feature.