8 | Mobile Banking and Payments:
What are the Rules?

Technology is evolving at an increasing rate. Banks are implementing mobile banking and payments products much faster than new regulations can be written. In order to meet compliance expectations with mobile banking and payment products, banks must apply “old” rules to new technology.

BY MEG SCZYRBA, CRCM, AND THOMAS HEALY, CRCM

14 | Exam Management: Do the
“Old Established” Principles
Still Apply?

Examinations have been a cornerstone “event” used to periodically gauge the health of the banking industry. Today, when we talk to colleagues about exams, it seems the term “periodically” is evolving into “continuously.” Despite tumult in the process, established exam management principles still apply.

BY THOMAS HEALY, CRCM, AND BONITA JONES

24 | Operation SCRA:
Serving Our Service Members

Military personnel entering into active duty may experience a significant impact to their income stream. With The Servicemember’s Civil Relief Act (SCRA), the government has taken steps to protect these service members. Bankers need to understand this law and how it protects military members.

BY RICHARD HARVEY, CRCM, AND RYAN RASSKE

30 | RESPA/TILA Update:
What You Need to Know

The release of the combined Real Estate Settlement and Procedures Act (RESPA) and Truth in Lending Act (TILA) disclosures allows the industry and the public to begin to discern the new compliance landscape. Each statute is uniquely complex, and the implementation of these regulatory reforms will be extremely challenging.

BY ROD ALBA AND HOLLIS BECKNER

Thegoodnewsfor complianceofficers isthatmostofthese mobilepaymentsare processedjustlike anyotherpayment madeorreceived.

MOBILE BANKING AND PAYMENTS

What are the Rules?

BY MEG SCZYRBA, TECHNOLOG Y IS EVOLVING mobilebankingandpaymentsp ordertomeetcomplianceexpe mustapply“old”rulestonewt for compliance oversight as they consid risks involved generally and as they appl capture.It will also provide an overview

Trends in Mobile Banking

Mobile banking and payments are rapidly expandin market. As consumers we can now send a split chec office mates after sharing lunch and reply by bumpin facilitate a payment or (less dramatically) sending a Person (P2P) payment. We can donate money by se message (think Haiti Relief!) for which our cell prov us later. Text messages can also come from our ban to possible fraud. We can deposit a check from any Remote Deposit Capture (RDC). We can also mak on our phones through “in app” payments, such Starbucks and other merchants have developed an us prepay our account and then swipe our phone a to checkout. Our phones may contain a microchip us to swipe the phone near a data receiver to pay f at a store using Near Field Communications techno Or you can attach a sticker to your phone that w similarly. Small merchants can acceptour credit car anywhere their smart phone will work with applic as Square. And banks have apps that allow us to acc directly from our phones now too.

Initiating Mobile Services (Authentication and Disclosures)

SHUTTERSTOCK

The good news for compliance officers is thatm payments are processed just like any other payme received. As such, we can focus our efforts on tho which require us to rethink the application of our old new technology, including RDC, P2P, and bank app

8 | ABA BANK COMPLIANCE | SEPTEMBER-OCTOBER 2012

MANAG EMENT

Do the “Old Established” Principles Still Apply?

THNKSTOCK

EXAMINATION MANAGEMENT PRINCIPLES
PRINCIPLE #1: Examination management should be a formal
component and ongoing element of an effective compliance
program. (Formalize exam management as an ongoing
control)
PRINCIPLE #2: Careful planning, solid compliance programs,
and good organization can turn most examinations into a
positive experience for the financial institution. (Effective
program and exam preparation)
PRINCIPLE #3: Substantive and effective communication
at all levels of the institution is essential to successful
examination. (Effective communication with stakeholders)
PRINCIPLE #4: Establishing and maintaining positive relations
with regulators is an integral element of examination
management and facilitates each of the other principles.
(Maintain positive relationships)