R. Kinney Williams
& Associates

Internet Banking News

July 22, 2001

INTERNET COMPLIANCE - Electronic Delivery of Federally Mandated Disclosures

The Federal Reserve Board published interim final rules to establish uniform standards for the electronic delivery of federally mandated disclosures under five consumer protection regulations: B (Equal Credit Opportunity), E (Electronic Fund Transfers), M (Consumer Leasing), Z (Truth in Lending), and DD (Truth in Savings).

Under the rules, financial institutions, creditors, lessors, and others may deliver disclosures electronically if they obtain consumers' consent in accordance with the requirements of the Electronic Signatures in Global and National Commerce Act (the "E-Sign Act"), enacted in June 2000. The Board's interim rules provide guidance on the timing and delivery of electronic disclosures, consistent with proposed rules issued by the Board in August 1999, to ensure consumers have adequate opportunity to access and retain the information.

INTERNET SECURITY - We continue the series from the FDIC "Security Risks Associated with the Internet" about the primary technical and procedural security measures necessary to properly govern access control and system security.

Product Certification and Security Scanning Products

Several organizations exist which independently assess and certify the adequacy of firewalls and other computer system related products. Typically, certified products have been tested for their ability to permit and sustain business functions while protecting against both common and evolving attacks.

Security scanning tools should be run frequently by system administrators to identify any new vulnerabilities or changes in the system. Ideally, the scan should be run both with and without the firewall in place so the firewall's protective capabilities can be fully evaluated. Identifying the susceptibility of the system without the firewall is useful for determining contingency procedures should the firewall ever go down. Some scanning tools have different versions with varying degrees of intrusion/attack attempts.

PRIVACY - July 18, 2001 - Examination Procedures to Evaluate Compliance with the Guidelines to Safeguard Customer Information - This bulletin transmits examination procedures for reviewing a national bank's compliance with "Guidelines Establishing Standards for Safeguarding Customer Information" (guidelines).
Press Release - www.occ.treas.gov/ftp/bulletin/2001-35.txt
Attachment - www.occ.treas.gov/ftp/bulletin/2001-35a.pdf
Attachment - www.occ.treas.gov/ftp/bulletin/2001-35b.pdf

Company Information
Yennik, Inc.
4409 101st Street
Lubbock, Texas 79424
Office 806-798-7119
Examiner@yennik.com

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