This Manual is a valuable resource for all operations personnel, compliance
officers, in-house counsel, and internal auditors, providing a comprehensive
discussion of applicable California and federal 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; and
- 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; and
- 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;
- Electronic disclosures in consumer lending and deposit operations; and
- FFIEC social media guidance.
The main text of the Manual is 499 pages, plus 36 pages of appendixes.
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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 #5, 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
info@bankerscompliancegroup.com or call 949-553-0909.
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