Internet Banking News December 19, 1999 FYI -The Federal Reserve Board announced the reopening and extension of the comment period on proposals to allow electronic delivery of federally mandated disclosures. On September 14, 1999, the Board published revised proposals for public comment 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). Comment is requested by March 3, 2000. http://www.bog.frb.fed.us/boarddocs/press/BoardActs/1999/19991209/ FYI - I learned at a conference that it would take the CIA 35 years to crack 128 bit encrypted data; whereas, it would take a teenage two weeks to crack 40 bit encrypted e-mail. It sure appears that using the 128 bit encrypted data is pretty safe. FYI - This week a banker contacted us about auditing their web site because the bank examiners criticized the bank's informational site. The bank is $10 million in assets, and the web site contains five web pages. INTERNET SECURITY - Internal controls over Internet banking systems should be commensurate with an institution's level of risk. As in any other banking area, management has the ultimate responsibility for developing and implementing a sound system of internal controls over the bank's Internet banking technology and products. The regulators in their Internet examination procedures state that regular audits of the control systems will help ensure that the controls are appropriate and functioning properly. For example, the control objectives for an individual bank's Internet banking technology and products might focus on: 1) Consistency of technology planning and strategic goals, including efficiency and
economy of operations and compliance with corporate policies and legal requirements. Once control objectives are established, management has the responsibility to install the necessary internal controls to see that the objectives are met. Management also has the responsibility to evaluate the appropriateness of the controls on a cost-benefit basis. That analysis may take into account the effectiveness of each control in a process, the dollar volume flowing through the process, and the cost of the controls. INTERNET COMPLIANCE - The OCC's Internet Banking handbook addresses the bank's
compliance with applicable banking laws as follows: Thank you for all your support. As we move in into the new year, we will work hard to help you maintain a compliant web site and assist your bank with its Internet activities. We will not publish a newsletter over the holiday weekend but will be back the first week in January. We hope you have a wonderful and blessed holiday season. |
