The FFIEC Has its Say on Authentication Guidance
What Will Your Risk Assessment Say about Your Institution’s Readiness for 2012?
By Lori Moore, CRCM, Director of Compliance

When the Federal Financial Institutions Examination Council (FFIEC) published its Supplement to Authentication in an Internet Banking Environment on June 28th, it sent tongues wagging throughout the financial services industry. How different was this final guidance from the draft released in December, 2010? Are the authentication guidelines strong enough? Does it address the environment of mobile banking? Do financial institutions have enough time to implement the guidelines prior to the January 1, 2012 effective date? The list could go on and on with the questions differing depending upon your role and position in the industry. The one thing that nearly everyone agrees on, from internet security experts and risk management gurus to banking-related associations, is that the first and best place for financial institutions to start their preparations for 2012, and to maintain the ongoing security of their electronic bank offerings, is with their Risk Assessment. As the core of your institution’s security plan, it has the power to say you’ve got this situation under control or you don’t. What will your Risk Assessment say about your institution?




Reg E: Are You in Compliance?

The Electronic Funds Transfer Act, implemented by Regulation E (Reg E), establishes the basic rights, liabilities and responsibilities of consumers who use electronic fund transfer (EFT) services and of the financial institutions that offer such. Without a doubt, it is one of the most complex consumer compliance laws in effect today. As the rapid shift from paper to electronic payments is expected to continue, your institution should anticipate and be prepared for the number of claims subject to Reg E to also increase. In this webinar, we will discuss various aspects of the law with emphasis on the error resolution procedures set forth under section 205.11. We will also look at important terms defined under Reg E and some example scenarios that illustrate common violations you want to avoid. 

Speaker: 

Lori Moore, CRCM
Director of Compliance
ATTUS Technologies

8/18/2011 3:00PM to 4:00PM ET

Question: With regards to voice response transfers from savings to checking, if that is subject to Regulation E, then technically that customer should receive a savings account statement each month when a transfer is made, correct?

Answer:  
For transfers between accounts held by the same consumer at the same financial institution, documenting the transfer on a periodic statement for one of the two accounts satisfies the periodic statement requirement. Therefore, provided your institution is sending monthly statements for checking accounts, the interim savings statement would not be necessary. This, as well as other exceptions to the periodic statement requirements can be found under section 205.9 (C).   

Got a question on a tricky regulation? We want to hear from you.   Submit your question and an expert will answer it in a future issue.



Just For Financial Institutions
Safe Systems Requests Your Participation in a Compliance Examination Survey

As part of an additional compliance tool for your financial institution, we would like you to participate in a brief (< 5 min.), anonymous survey on your most recent compliance examination. This survey is designed to be a valuable resource as you prepare for future exams. Our intent of this survey is to make the aggregate results available to you as a sort of “early-warning radar.” For example, we might see a pattern develop where institutions less than $100M in size located in certain geographic areas were generally experiencing increasing levels of examiner scrutiny overall. We will compile these findings, and present them to you on an upcoming post on our Compliance Guru website. Additionally, if you prefer, there is an option to have the final results of the survey emailed directly to you. Please click here to start the survey.

The Federal Reserve Bank's Annual Report
Take Reasonable Risk-Based Steps
Department of Treasury, FinCEN.gov

The Financial Crimes Enforcement Network (FinCEN) is issuing this Advisory to U.S. financial institutions to take reasonable risk-based steps with respect to the potential increased movement of assets that may be related to the current unrest in Syria.

During this period of uncertainty, FinCEN is issuing this Advisory to remind U.S. financial institutions of their requirement to apply enhanced scrutiny for private banking accounts held by or on behalf of senior foreign political figures and to monitor transactions that could potentially represent misappropriated or diverted state assets, proceeds of bribery or other illegal payments, or other public corruption proceeds. Read more...



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