Circular
Interagency Council Guidance On Electronic Financial Services and Consumer Compliance
July 31, 1998
Circular No. 11078

To the Chief Executive Officers of State Member Banks in the Second Federal Reserve District:

The following is from a press release issued by the Federal Financial Examinations Council (FFIEC)

The Federal Financial Institutions Examination Council (FFIEC) has issued industry guidance on the consumer regulatory implications of emerging electronic banking technologies.

The guidance provides federally insured depository institutions with 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 to monitor electronic banking operations to ensure that those operations are in compliance with applicable laws, regulations, and policies.

The "Guidance on Electronic Financial Services and Consumer Compliance" (pdf) contains two sections:

Compliance Regulatory Environment summarizes relevant sections of the federal consumer protection laws and regulations that address electronic financial services, and includes interim compliance policy guidance with examples of the application of 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.

Questions on this matter may be addressed to Janice A. Oser, Examining Officer (212-720-8136), at this Bank.