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What customers need to be told

By Dan Hadaway | Tuesday, August 27, 2013 - Leave a Comment

According to the Federal Financial Institutions Examination Council’s (FFIEC), a financial institution’s customer awareness and educational efforts should address both retail and commercial account holders and, at a minimum, include the following elements:

  • An explanation of protections provided and not provided to account holders relative to electronic funds transfers under Regulation E, and a related explanation of the applicability of Regulation E to the types of accounts with Internet access;
  • An explanation of under what, if any, circumstances and through what means the institution may contact a customer on an unsolicited basis and request the customer’s provision of electronic banking credentials;
  • A suggestion that commercial online banking customers perform a related risk assessment and controls evaluation periodically;
  • A listing of alternative risk control mechanisms that customers may consider implementing to mitigate their own risk, or alternatively, a listing of available resources where such information can be found; and,
  • A listing of institutional contacts for customers’ discretionary use in the event they notice suspicious account activity or experience customer information security-related events.

 


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