Internet Banking News
September 26, 1999
TEXAS BANKERS - Effective September 1, 1999, contracts made over the
Internet with out-of-state parties are subject to Texas laws. Check with your legal
council for the wording they would recommend, but I would suggest making the statement on
any contract "That this contract is subject to the laws of Texas." even though
the law will cover without the statement. You will find a copy of the new law at http://www.bankwebsiteaudits.com/texas_hb_bill_2653.htm.
INTERNET COMPLIANCE - Financial institutions that advertise deposit products and services
on-line must verify that proper advertising disclosures are made in accordance with all
provisions of §230.8. Institutions should note that the disclosure exemption for
electronic media under §230.8(e) does not specifically address commercial messages made
through an institution's web site or other on-line banking system. Accordingly, adherence
to all of the advertising disclosure requirements of §230.8 is required.
Pursuant to §230.3(a), disclosures generally are required to be in writing and in a form
that the consumer can keep. Until the regulation has been reviewed and changed, if
necessary, to allow electronic delivery of disclosures, an institution that wishes to
deliver disclosures electronically to consumers, would supplement electronic disclosures
with paper disclosures.
FYI - Truth-in-savings requires that disclosures be delivered prior to an account being
opened. If you are opening accounts and/or taking deposit applications, you should have a
link to the bank's truth-in-savings disclosures. Even with the link, you should indicate
that you will mail the proper disclosures when the deposit application is received by the
bank.
INTERNET SECURITY - There is a book entitled "Intrusion Detection: An Introduction to
Internet Surveillance, Correlation, Trace Back, Traps, and Response " by Edward
Amoroso that should be required reading for Security Administrators. This book can be read
by persons that do not have a computer background but want to obtain a basic knowledge of
network and Internet security. Dr. Amoroso works for AT&T Laboratories. He covers many
of the issues discussed in the FDIC Issues Paper on Information System Security Issues
dated July 7, 1999.
WEB PAGES - Web pages are a form of advertisement of your bank's products. The web site
provides information to attract new business and for current customers. I believe that web
pages should be fast loading and to the point. I have read that within 20 seconds a
visitor will move on to another site because the home page takes too long to load. So once
the visitor has found your site, you do not want them leaving because they get bored
waiting for the page to load. |
