These online bank accounts are protected to varying degrees by one or more security procedures (e.g., user IDs and passwords, challenge questions, token codes, risk scoring and monitoring, customer notification, etc.). Article 4A of the Uniform Commercial Code (Article 4A) sets forth the rights, duties and liabilities of banks and their commercial customers with respect to funds transfers. the types of security procedures generally in use by similarly situated banks and customers. Bank employees should receive comprehensive training on the bank's security procedures and how to properly respond in the unfortunate circumstance when fraudulent online transactions are acted upon by the bank prior to the cybercriminals' activities being discovered. The safety of our customer’s funds and transaction processing is paramount. In addition, there should be board approved documented policies and procedures addressing dual control for ATM access as well as maintenance, security procedures, patch management, network security, and fraud monitoring and protection. This easy access to financial accounts makes Internet banking a common target for hackers and other online criminals, however. Receipting and Banking Procedures 2018 Page 2 of 6 merchant means the holder of a banking facility that enables the holder to accept payments by debit payment card, credit payment card or EFTPOS. The number, type and extent to which these security procedures are employed will often depend on the capabilities of the bank and the needs and financial resources of a particular commercial customer. OTHER FORMS OF ELECTRONIC BANKING. 9 policies and procedures you need to know about if you’re starting a new security program Any mature security program requires each of these infosec policies, documents and procedures. If the bank acts on any of these unauthorized payment orders, the question becomes who should bear the risk of loss for any funds of the customer that cannot be recovered – the customer or the bank? For example, cybercriminals are often able to use phishing emails and various types of malicious software (malware) to obtain confidential banking information (e.g., user IDs, passwords and answers to challenge questions) from the individual users of a commercial customer's online bank accounts. BENEFITS/CONCERNS OF E-BANKING BENEFITS OF E-BANKING For Banks: Price- In the long run a bank can save on money by not paying for tellers or for managing branches. electronic transactions between customers and their bank. It remains to be seen to what extent the Ocean Bank and Comerica Bank decisions will be used by other courts to question the sufficiency of a bank's online security procedures and/or hold a bank responsible for commercial customer losses resulting from fraudulent electronic transactions initiated by cybercriminals in circumvention of such security procedures. As such, these recent decisions should serve as a reminder to all banks that they need to remain steadfast and proactive in their commitment to providing sufficient protection for their commercial customers' online bank accounts. Electronic banking, more commonly known as e-banking, is the newest delivery channel for banking services. CONSUMER AFFAIRS ELECTRONIC BANKING EXAMINATION CHECKLIST This checklist was established by the Electronic Banking Working Group (EBWG) to create a tool for examiners to document reviews of a state member bank’s Internet web site for compliance with applicable consumer protection laws and regulations. With this information, these criminals can then attempt to access the customer's online bank accounts and, if successful, initiate fraudulent payment orders for substantial sums of money. Security Procedures Consider this scenario, while keeping security procedures at your organization in the back of your mind. In theory, these security procedures are intended to provide benefits to both the bank and its customers. the wishes of the customer expressed to the bank; the circumstances of the customer known to the bank, including the size, type and frequency of payment orders typically issued by the customer; whether alternative security procedures were offered to, but not elected by, the customer; and. take a payment through an electronic payment terminal handle a card number read to you over the phone handle a card number received in a letter … Article 4A provides the answer to this risk of loss question. Why One Size Doesn't Fit AllBy Joshua R. Hess (Published in the Winter 2013 issue of The Bankers' Statement.). Some states and municipalities have specific limits. PayOnline means the University’s cashiering system used to record revenue transactions and refunds. the bank had prior notice that phishing emails had been sent out to its customers; the time it took the bank to stop processing the fraudulent payment orders (over six hours after the first order was received by the bank); EMI's limited history of placing online payment orders (only two had been previously placed); the volume and frequency of the fraudulent orders that were placed; and. On the other hand, if it is found that any one or more of these elements have not been met, then the risk of loss will shift to the bank and it will be the bank that is required to refund to the customer all amounts that were transferred out of the customer's bank accounts as a result of the fraudulent electronic payment orders and not otherwise recovered. Banking via the Internet is an easy way to monitor your business’s finances, allowing you to view payments and deposits on demand. Many banks and credit unions allow customers to get text and email alerts about certain transactions in their accounts. In theory, these security procedures are intended to provide benefits to both the bank and its customers. Establishing such an agency relationship would be unlikely. : 9425086395 ABSTRACT In its very basic form, E-banking can mean the provision of information about a bank and its services via a home page on the World Wide Web (WWW). Information Security Policies, Procedures, Guidelines Revised December 2017 Page 6 of 94 PREFACE The contents of this document include the minimum Information Security Policy, as well as procedures, guidelines and best practices for the protection of the information assets of the State of Oklahoma (hereafter referred to as the State). LEXIS 62677 (E.D. Plus, it’s cheaper to make transactions over the Internet. With respect to the good faith requirement, the court noted that the burden of proof under Article 4A was on the bank to establish: The court found that Comerica Bank had failed to set forth any evidence that this second element of good faith had been established. For the bank, the security procedures offer greater assurance that the online payment orders issued in a customer's name are in-fact authorized by such customer and can be safely acted upon. (a) Authority, purpose, and scope. that the processing of such fraudulent payment orders comported with reasonable commercial standards of fair dealing (i.e., that the bank's response and processing of the payment orders was in-line with what other similarly situated banks would have done if one of their customers was victimized by a phishing scheme). æó×1ŠøœCô ç¦‘yŒB¸H†©& gáy. Although this scenario seldom occurs, it’s a possibility that shouldn’t be ruled out … There’s been talk about a strike due to the possibility that your organization may be seeking concessions. Ultimately, the court ruled that the security procedures used by Ocean Bank were not “commercially reasonable” for the purpose of protecting Patco's accounts. E-Banking. Network firewalls fulfill the same role within the realm of cyber security. Those protections included log-in IDs and passwords, computer tracking cookies, risk profiling and scoring reports, and challenge questions triggered for high-risk transactions or transactions over certain dollar amounts. Experi-Metal, Inc. (EMI), a Michigan-based metal fabricating company, was the victim of an email phishing scheme wherein cybercriminals obtained the log-in information of EMI's controller and used such information to initiate 93 fraudulent online payment orders totaling more than $1.9 million. Banking should be prepared by one officer and checked by another who will endorse the total of the banking in each receipt … Several members of your executive team have been threatened. the bank acted on the payment order which turned out to be fraudulent in good faith and only after verifying its authenticity in compliance with such security procedures. 20783 Abstract The Internet has played a key role in changing how we interact with other people and how we do business today. Electronic payments are considered to be more secure for a number of reasons, including: • They are secure and encrypted and can be protected with a secure one-time password (OTP) and with multilevel authorisations and approvals. In the case, the court discussed the bundle of security measures that Ocean Bank employed for Patco's online bank accounts. that its employees did in-fact act honestly when processing the fraudulent payment orders (i.e., that they had a “pure heart and empty head”), and. While the Brattleboro Savings & Loan has implemented a number of security features to make your online banking experience as safe as possible, it is important that you as a consumer do Staff Integrity. Direct Deposit Electronic Bill Payment Electronic Check Conversion Cash Value Stored, Etc. THE SECURITY OF ELECTRONIC BANKING Yi-Jen Yang 2403 Metzerott Rd. Complete collections for a day should be recorded so as to be readily identifiable with the bank deposit or deposits in respect of that day. The bank, Comerica Bank (then the 31st largest bank in the U.S. by total assets), had implemented various security procedures to protect EMI's accounts, such as user IDs and passwords, challenge questions and token codes, and had also established an internal bank policy for responding to fraudulent payment orders initiated through phishing schemes. Enhanced Transaction Security: An additional security procedure that may be required by Bank includes the use of one-time pass-codes for certain transactional functionality associated with ACH transactions and wire transfers. that the recipients of all of the payment orders were located in foreign countries notorious for higher instances of cybercrime. Instead, as noted by the court, the evidence suggested that it was unlikely that the banks response and actions did comport with reasonable commercial standards of fair dealing given, among other things: As a result, the court found that the good faith requirement under the Article 4A risk of loss test had not been met and, therefore, Comerica Bank bore the risk of loss for $560,000 in EMI funds that could not be recovered. To prevent confusion and disagreements, make sure you establish security deposit policies and procedures that address the following: Amount: Usually no more than the equivalent of one- or two-month’s rent. Security Issues Relating to Internet Banking. Mich. June 13, 2011), the U.S. District Court for the Eastern Division of Michigan also considered whether the security procedures implemented by a bank with respect to a particular commercial customer's online bank accounts passed muster under Article 4A's risk of loss test. Examination Guidance on the Safety and Soundness Aspects of Electronic Banking Activities With the increasing emergence of electronic banking, and the associated risks to the safety and soundness of insured financial institutions offering such products and services, the FDIC has developed electronic banking examination procedures for its staff. Computer hackers can get access to a bank account due to password or pin number leakage. In reaching this decision, the court found the following failures of Ocean Bank's security, when considered collectively, to be determinative: In making this decision, the court also noted that the bank's reliance on challenge questions without implementing additional layers of security was cautioned against by bank regulators and by the third-party vendors that supplied such security software, not common amongst New England community banks in combating the ever-growing problem of internet fraud, and especially unreasonable given the fact that the bank had itself previously been the victim of fraud involving keylogging malware. It includes the requirement for unique credentials (a Company ID, a User ID, and a Password) and also uses complex device identification processes at each login. To do this, the bank would need to show that there was some type of pre-existing relationship between the customer and the cybercriminal that justifies holding the customer responsible for the cybercriminal's actions (e.g., if the cybercriminal was a customer insider). The opinions of those courts, and the implications that these decisions could have for online security procedures and bank liability going forward, are discussed in further detail below. E-BANKING MANAGEMENT: IMPACT, RISKS, SECURITY Mrs. Bhavna Bajpai* (Lecturer Shri Dadaji Institute of Technology & Science, Khandwa(M.P.)) A Guide to Online Banking Security Practices and Procedures For a safer online experience it is important to understand the threats that exist on the internet. Electronic payments Why are they secure? As one could imagine, commercial customers incurring significant financial losses as a result of fraudulent electronic payment orders may decide to file lawsuits against their banks in an effort to recover funds lost due to the online fraud. What is certain, however, is that the instances and complexity of cybercrime affecting the U.S. online banking system continues to rise at an alarming pace, and the amount of potential losses that banks could be subject to for implementing inadequate security procedures are considerable. This paper will first discuss the drivers of e-banking; … For the bank, the security procedures offer greater assurance that the online payment orders issued in a customer's name are in-fact authorized by such customer and can be safely acted upon. Online banking, also known as internet banking or web banking, is an electronic payment system that enables customers of a bank or other financial institution to conduct a range of financial transactions through the financial institution's website. Ý͟yð¿ÏbîzöíŸ7o> ¤ÕMÝ81¦w˜elâ¹a`ŒeKø cömóÝùßxÞÝG>å7‰ÝÈä×sƒ4!V鰑à—ÅRD‘³ÂÄy‚8r²É"¯Å÷75ÈbÈçŸôÇs“ÐÇ1lÄFn@Lzn2à+N³*»y³ûû͛Óëƒ$u}&b7ˆ´DÚE@pÚEäÔÍ"&R‡/–¡ãÁþ©‡7&7Ú 0Ã>|~ÇØÝT±Ïï>½gž¡7$2f“‰Ë}%ŠjJxBÒ7H Legally there is no difference between electronic financial transactions and cash transactions, and your online security must comply with national and state laws. Under Article 4A, the risk of loss for any payment order fraudulently initiated by a cybercriminal and acted upon by a bank will generally fall on the customer in whose name such payment order was issued if all of the following elements are met: With respect to determining whether certain security procedures are “commercially reasonable,” Article 4A requires that the following factors be considered: If each of the three elements identified above are met, then the risk of loss for any damages incurred by the commercial customer as a result of the bank acting on a fraudulent payment order from a cybercriminal will generally be borne by the customer, as Article 4A deems it ultimately the customer's “fault” for allowing a third-party (i.e., the cybercriminal) to improperly obtain access to the customer's online bank accounts despite adequate security measures being in place and followed by the bank. § 326.4] Subpart B—Procedures for Monitoring Bank Security Act Compliance § 326.8 Bank … The Security Procedures agreed upon by the parties for verifying the authenticity of Wire Transfers is the use of a log-in identification code (“User ID”), unique authentication code(s) (“Password”) and Secure Access Code. A sound program should have a physical and logical security and risk awareness program in place. Customers can confirm their password log-in with an additional security code that is texted to your mobile phone or other device – known as “two step verification” or “two factor authentication”. And your concerns are … For a customer, the security procedures serve as a safeguard against unauthorized access to and use of such customer's bank accounts and confidential information. LEXIS 13617 (1st Cir. In the June 2011 case of Experi-Metal, Inc. v. Comerica Bank, 2011 U.S. App. However, since June 2011, at least two federal courts have ruled that a bank's security procedures did not satisfy Article 4A's requirements and, therefore, the bank could be held liable for acting on fraudulent electronic payment orders. An ATM is an electronic communication device and, therefore, the controls … The security of internet banking is primordial while banking through the internet. The security of one’s bank account is related straightforwardly to a great extent to one’s security of computer including password and pin number. As a result, the court held that Ocean Bank could be found liable for over $345,000 in losses from Patco's bank accounts caused by fraudulent payment orders placed over a period of seven days by a cybercriminal who used keylogger malware to steal confidential banking information (usernames, passwords and answers to challenge questions) from Patco employees. Today, the vast majority of funds transfers occur electronically (i.e., by wire transfer) through the placement of payment orders by commercial customers via their online bank accounts. The court also stressed those security measures that were not implemented for Patco's online bank accounts, including, among other things, bank monitoring of the risk-score reports that were generated, and manual review and customer notification of high risk-scoring transactions. In a recent case, Patco Construction Company, Inc. v. People's United Bank (d/b/a Ocean Bank), 2012 U.S. App. If you work within the banking industry, writing effective information security policies is more than laying out a set of rules to follow. The union’s contract is ready to expire. Finally, proper documentation should be generated by the bank at all stages of the security procedure assessment, selection and implementation process. [Codified to 12 C.F.R. Risk assessments should be conducted on a periodic basis to determine if the number, types and combinations of online security procedures employed by the bank (either internally or through third-party vendors) are sufficient in light of recent threats, current technology, customer awareness and regulatory guidance.1   Applicable bank policies should be reviewed and, if necessary, revised to ensure that such online security procedures are being offered and implemented on a personalized, customer-by-customer basis after thorough analysis of whether such procedures are commercially reasonable for a particular customer. 2. Adelphi, MD. Due date: Usually […] July 3, 2012), the U.S. Court of Appeals for the First Circuit found that the security procedures implemented by a New England community bank, Ocean Bank (later acquired by People's United Bank), with respect to the online bank accounts of Patco Construction Company (Patco), a small property development and contractor business, were not “commercially reasonable” within the parameters of Article 4A. This booklet, one of several comprising the FFIEC Information Technology Examination Handbook (IT Handbook), provides guidance to examiners and financial institutions on identifying and controlling the risks associated with electronic banking (e-banking) activities. We invested in the best security, technology and major payment gateways to make deposits and withdrawals and all other banking procedures … The security officer for each institution shall report at least annually to the institution's board of directors on the implementation, administration, and effectiveness of the security program. © 2021 Vorys, Sater, Seymour and Pease LLP. When reviewing an ATM program both physical and logical controls should be considered. The term had been defined in many ways by researchers mainly because electronic banking refers to several types of services through which customers can request One of the most common sources of landlord-resident disputes is the return of security deposits. Until recently, it appears that customers were largely unsuccessful in bringing such lawsuits. As a result of the Internet, electronic commerce has … the customer and the bank have agreed that the authenticity of payment orders issued to the bank in the name of the customer will be verified by the bank prior to acceptance pursuant to agreed-upon security procedures; such security procedures are “commercially reasonable”; and. Read the Queensland Electronic Transactions Act 2001 and Australian Electronic Transactions Act 1999 (Cwlth). Ally Law (International Alliance of Law Firms), Information Technology, New Media and Advertising, Intellectual Property, Entertainment, and Technology Protection. The only exception to this shifting of the risk of loss onto the bank would be if the bank could establish that the customer was nonetheless bound by the fraudulent payment orders under the law of agency. 1882), member banks are required to adopt appropriate security procedures to discourage robberies, burglaries, and larcenies, and to assist in the identification and prosecution of persons who commit such acts. The first line of defense at a bank is the front door, which is designed to allow people to enter and leave while providing a first layer of defense against thieves. The bank and the customer agree that the funds transfer will be verified pursuant to a security procedure, The bank’s security procedure is a commercially reasonable method of providing security against unauthorized payment orders, and The bank proves that it accepted the payment order in good faith and in compliance with the security procedure. Some of the most common security measures for online banking include the following: Customers log in with a password. Banking procedures at FXStockBroker are safe and secure. Unfortunately, due to the drastic increase and sophistication of cybercriminals, a commercial customer's online bank accounts may still be susceptible to improper access and use despite the customer and bank's adherence to one or more agreed-upon security procedures. The challenges that oppose electronic banking are concerns of security and privacy of information. Nonetheless, the court held that the risk of loss test had not been satisfied because the bank had not set forth evidence that it had acted in good faith in processing the fraudulent payment orders. Email: bhavna_khatri2006@yahoo.co.in Mobile No. Pursuant to section 3 of the Bank Protection Act of 1968 (12 U.S.C. Advanced Login Authentication is a standard and required part of every login to Business Online Banking. 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