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Today is: October 18, 2018  

Compliance Companion®
Standard Procedures Manuals (SPM)

Electronic Banking February 2018

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 virtually 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 notice and opt-in requirements in connection with ATM and one-time debit card transactions
  • Consumer international remittance transfer requirements
Part Two provides debit card operations and disclosures requirements, including limitations on liability for unauthorized use under Regulation E as well as under the Visa and MasterCard rules.

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). This discussion includes:
  • Operation of the Automated Clearing House, including the NACHA Rules
  • NACHA authorization and notice requirements
  • Same Day Settlement
  • 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 with electronic banking
  • Cash management services and contract management
  • Online and mobile banking, including mobile payments and deposits
The text of the Manual is 489 pages, with 136 pages of appendices (sample and model forms, FFIEC guidance, funds transfer risk checklist, etc.).


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