OCC Bulletin 1998-31| July 30, 1998
Guidance on Electronic Financial Services and Consumer Compliance: FFIEC Guidance
Chief Executive Officers and Compliance Officers of all National Banks, Department and Division Heads, and all Examining Personnel
The guidance attached to this bulletin continues to apply to federal savings associations.
The Federal Financial Institutions Examination Council (FFIEC) issued the attached interagency guidance on the consumer regulatory implications of emerging electronic banking technologies.
The guidance gives federally insured depository institutions information on federal consumer protection laws and regulations, and their application to electronic financial service operations. Many of the general principles, requirements, and controls within the current consumer protection regulatory framework apply to financial services conducted electronically. This guidance should help financial institutions monitor electronic banking operations and ensure that those operations are in compliance with applicable laws, regulations, and policies.
The guidance contains two sections:
"Compliance Regulatory Environment" summarizes relevant sections of the federal consumer protection laws and regulations that address electronic financial services. It also includes interim compliance policy guidance with examples of how to apply the existing consumer laws and regulations.
"The Role of Consumer Compliance in Developing and Implementing Electronic Services" discusses the importance of compliance officer involvement in the design, development, implementation, and monitoring of electronic banking operations.
The Federal Reserve Board of Governors recently published proposed rules that may, in the future, result in modifications to certain consumer protection regulations. The FFIEC will issue further guidance, if necessary, to address any significant future changes to federal consumer protection regulations.
For more information, call Carol Workman, compliance specialist, at (202) 874-4858.
Stephen M. Cross
Community and Consumer Policy