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Remote Deposit Capture Risk Management Regulatory Guidance: Implications for Wholesale BankingProduct Type: Market Research ReportPublished by: TowerGroup Published: February 2009 Product Code: R301-1598 Description The Federal Financial Institutions Examination Council (FFIEC) guidance on remote deposit capture (RDC) risk contains prescriptions for assessing individual customer risk, including onsite reviews of high-risk customer environments. The FFIEC guidance references existing security guidelines for data privacy and authentication, including an explicit statement that single-factor authentication for RDC solutions that use the Internet for communications is not sufficient. Detailed recommendations for content to be included in customer agreements in order to mitigate legal risk are part of the guidance. This new guidance has potentially far-reaching consequences in that it places responsibility on the bank for approving the suitability of a particular client rather than relying entirely on contracts that allocate liabilities. For wholesale banking providers that offer RDC to clients, the issuance of the guidance represents an opportunity to evaluate bank-specific RDC risk management policies and procedures in light of the guidance and make appropriate adjustments. Each bank needs to establish a team to assess current compliance, communicate internally and with vendors and clients, develop a plan to meet the new guidelines, and coordinate with the examiners. Table of Contents
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