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Compliance Companion®
Standard Procedures Manuals (SPM)

Electronic Banking November 2023

This Manual is a valuable resource for all operations personnel, compliance officers, in-house counsel, and internal auditors, providing a comprehensive discussion of the laws and regulations affecting essentially all aspects of electronic banking.

Part One of the Manual contains a detailed discussion of the Electronic Fund Transfers Act and Regulation E, including:

  • Regulation E requirements regarding consumer transfers, such as the issuance of access devices, initial disclosures, change-in-terms notices, error resolution procedures and preauthorized transfers
  • Overdraft disclosure and opt-in requirements in connection with automated overdraft protection programs involving ATM and one-time debit card transactions
  • Consumer international remittance transfer requirements
  • Prepaid account rule
  • Laws governing ATMs
Part Two examines debit card operations and disclosure requirements, including limitations on liability for unauthorized use under Regulation E, as well as under the Visa and MasterCard rules, various other debit card issues, and the Durbin Amendment.

Part Three discusses NACHA’s Automated Clearing House (ACH) as well as wire and other wholesale funds transfer systems under UCC Division 11 (Article 4A). Part Three covers these and other topics:
  • Operation of the Automated Clearing House, including the NACHA Rules
  • NACHA authorization and notice requirements
  • NACHA’s Meaningful Modernization rule changes
  • Same Day ACH Processing
  • Division 11 of the California Commercial Code
  • New FedNow Service
  • Risks involved with fraudulent wire transfers
  • Use and enforceability of commercially reasonable security procedures
  • The need for effective funds transfer agreements
Part Four covers cash management and online banking services, paying particular attention to the development of those services based on continuous changes in technology and the associated risks, including:
  • Privacy and security issues in connection with mobile banking
  • General issues involving electronic banking activities
  • Cash management services and contract management
  • Online and mobile banking, including mobile payments and deposits
  • Electronic disclosures in consumer lending and deposit operations
  • FFIEC social media guidance
The text of the Manual is 529 pages, with 43 pages of appendixes.


Compliance Companion

Compliance Companion® is a one-stop regulatory compliance resource for financial institutions. This online compilation of 19 industry-leading compliance manuals, including this SPM #05, Electronic Banking, takes the legalese out of federal and California laws and regulations, making it easier to understand and keep up with ongoing compliance developments.

Published by Aldrich & Bonnefin, PLC, Compliance Companion® has many useful features including search capabilities, links to internal cross-references and web-based sources, as well as samples of dozens of forms, disclosures and notices.

This compliance resource can also be accessed from your mobile device, making it faster and easier to get the latest information on federal and California laws and regulations governing financial institutions.

For information regarding online subscriptions to Compliance Companion®, contact or call 949-553-0909.

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* Janet Bonnefin is retired from the practice of law with the firm.
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