R. Kinney Williams & Associates
R. Kinney Williams
& Associates

Internet Banking News

March 9, 2003

FYI - Hackers broke into a University of Texas database and stole the names, Social Security numbers and e-mail addresses of more than 55,000 students, former students and employees, officials said.   http://www.salon.com/tech/wire/2003/03/06/crackers/index.html?x 

FYI CLIENTS - GAO report on the Critical Infrastructure Protection: Efforts of the Financial Services Sector to Address Cyber  http://www.gao.gov/new.items/d03173.pdf 

FYI - GAO report on Information Technology Training: Practices of Leading Private-Sector Companies.  http://www.gao.gov/new.items/d03390.pdf 

INTERNET COMPLIANCEElectronic Fund Transfer Act, Regulation E (Part 2 of 2)

Additionally, the regulations clarifies that a written authorization for preauthorized transfers from a consumer's account includes an electronic authorization that is not signed, but similarly authenticated by the consumer, such as through the use of a security code.  According to the Official Staff Commentary (OSC,) an example of a consumer's authorization that is not in the form of a signed writing but is, instead, "similarly authenticated," is a consumer's authorization via a home banking system.  To satisfy the regulatory requirements, the institution must have some means to identify the consumer (such as a security code) and make a paper copy of the authorization available (automatically or upon request).  The text of the electronic authorization must be displayed on a computer screen or other visual display that enables the consumer to read the communication from the institution. Only the consumer may authorize the transfer and not, for example, a third-party merchant on behalf of the consumer.


Pursuant to the regulations, timing in reporting an unauthorized transaction, loss, or theft of an access device determines a consumer's liability.  A financial institution may receive correspondence through an electronic medium concerning an unauthorized transaction, loss, or theft of an access device.  Therefore, the institution should ensure that controls are in place to review these notifications and also to ensure that an investigation is initiated as required.


INTERNET SECURITY
- We continue our coverage of the FDIC's "
Guidance on Managing Risks Associated With Wireless Networks and Wireless Customer Access."

Risk Mitigation Components - Wireless Internet Devices

For wireless customer access, the financial institution should institute policies and standards requiring that information and transactions be encrypted throughout the link between the customer and the institution. Financial institutions should carefully consider the impact of implementing technologies requiring that a third party have control over unencrypted customer information and transactions.

As wireless application technologies evolve, new security and control weaknesses will likely be identified in the wireless software and security protocols. Financial institutions should actively monitor security alert organizations for notices related to their wireless application services. They should also consider informing customers when wireless Internet devices that require the use of communications protocols deemed insecure will no longer be supported by the institution.

The financial institution should consider having regular independent security testing performed on its wireless customer access application. Specific testing goals would include the verification of appropriate security settings, the effectiveness of the wireless application security implementation and conformity to the institution's stated standards. The security testing should be performed by an organization that is technically qualified to perform wireless testing and demonstrates appropriate ethical behavior.

PRIVACY
- We continue our coverage of the various issues in the "Privacy of Consumer Financial Information" published by the financial regulatory agencies.

Financial Institution Duties ( Part 1 of 6)

The regulations establish specific duties and limitations for a financial institution based on its activities. Financial institutions that intend to disclose nonpublic personal information outside the exceptions will have to provide opt out rights to their customers and to consumers who are not customers. All financial institutions have an obligation to provide an initial and annual notice of their privacy policies to their customers. All financial institutions must abide by the regulatory limits on the disclosure of account numbers to nonaffiliated third parties and on the redisclosure and reuse of nonpublic personal information received from nonaffiliated financial institutions.

A brief summary of financial institution duties and limitations appears below. A more complete explanation of each appears in the regulations.

Notice and Opt Out Duties to Consumers:

If a financial institution intends to disclose nonpublic personal information about any of its consumers (whether or not they are customers) to a nonaffiliated third party, and an exception does not apply, then the financial institution must provide to the consumer:

1)  an initial notice of its privacy policies;

2)  an opt out notice (including, among other things, a reasonable means to opt out); and

3)  a reasonable opportunity, before the financial institution discloses the information to the nonaffiliated third party, to opt out.

The financial institution may not disclose any nonpublic personal information to nonaffiliated third parties except under the enumerated exceptions unless these notices have been provided and the consumer has not opted out. Additionally, the institution must provide a revised notice before the financial institution begins to share a new category of nonpublic personal information or shares information with a new category of nonaffiliated third party in a manner that was not described in the previous notice.

Note that a financial institution need not comply with the initial and opt-out notice requirements for consumers who are not customers if the institution limits disclosure of nonpublic personal information to the exceptions.

 

PLEASE NOTE:  Some of the above links may have expired, especially those from news organizations.  We may have a copy of the article, so please e-mail us at examiner@yennik.com if we can be of assistance.  

Back Button

Company Information
Yennik, Inc.

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

 

Please visit our other web sites:
VISTA penetration-vulnerability testing
The Community Banker - Bank FFIEC & ADA Web Site Audits
Credit Union FFIEC & ADA Web Site Audits - Bank Auditing Services
US Banks on the Internet  
US Credit Unions on the Internet

All rights reserved; Our logo is registered with the United States Patent and Trademark Office.
Terms and Conditions, Privacy Statement, Copyright Yennik, Incorporated