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8/19/2019 ebanking and its risk managment
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E-banking: concepts & risk management NLDIMSR
Contents
1. INTRODUCTION:........................................................................................................... ...........1.1 Banking Overview:................................................................................................................
1.2 E-Banking basics....................................................................................................................
1.3 Edge over traditional banking................................................................................................
1.4Drivers for chnage...................................................................................................................
1.5 ndia banks on web................................................................................................................
1.! Evol"tion of E-banking..........................................................................................................
1.# $or%s of E-banking.............................................................................................................
2. E-BANKING COMPONENTS....................................................................................... ..
2.1 E-banking strateg&...............................................................................................................
2.1 $actors infl"encing e-banking s&ste%..................................................................................
2.2 'ost Entities.........................................................................................................................
2.3 (o%)onents and *rocesses..................................................................................................
3. E-BANKING SUPPORT SERVICES............................................................................. ..
3.1 +eblinking...........................................................................................................................
3.2 ,cco"nt ,ggregation............................................................................................................
3.3 Electronic ,"thentication.....................................................................................................
3.4 +ebsite 'osting...................................................................................................................
3.5 *a&%ents for E-(o%%erce..................................................................................................
3.5.1 *erson-to-*erson *a&%ents........................................................................................
3.! +ireless E-Banking..............................................................................................................
4. E-BANKING RISKS........................................................................................................ ..
4.1 ransactiono)erations risk..................................................................................................4.2 (redit risk.............................................................................................................................
4.3 /i0"idit& interest rate )rice%arket risks............................................................................
4.4 (o%)liancelegal risk..........................................................................................................
4.5 trategic risk........................................................................................................................
4.! e)"tation risk.....................................................................................................................
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5. Risk Management............................................................................................................. ...........
5.1Board anage%ent.........................................................................................................
5.2ec"rit&...............................................................................................................................
5.3eg"lator& and /egal fra%ework.......................................................................................
8. A!antages "# E-Banking:..............................................................................................................
$. C%a&&enges an '"a a%ea:...........................................................................................................
(). C"n*&+si"n........................................................................................................................................
!. Re#e'en*e .......................................................................................................................... .......
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INTRODUCTION
(.( Banking O!e'!ie, :
ince 16#7 banking and finance have "ndergone nothing less than a revol"tion. he
str"ct"re of the ind"str& in the %id-1667s bore little rese%blance to that established in the1637s in the after%ath of the bank fail"res of the 8reat De)ression. n the 16#7s and
1697s what had been a fract"red s&ste% b& design beca%e a single %arket do%esticall&
and internationall&. his is largel& attrib"ted to the ado)tion of new technolog& in
banking sector
ndian banking and financial sector has witnessed blaing s"ccess and created a h"ge
o))ort"nit& for the ndian ind"str& both in the international %arket and also
do%esticall&. +ith the financial services sector alread& acco"nting for %ore than 35
)ercent of the ndian software and services sector the seg%ent is well geared-") to offer
c"sto%ied financial )rod"cts and services as )er the ndian do%estic %arketsre0"ire%ents
Banks are de)lo&ing in the following areas :
;(ore Banking
;,"to%ation of Branches
;Deliver& (hannels
;arketing
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;ec"rit&
;(ash anage%ent and *a&%ent services
;Data wareho"sing and Data %ining
;+ork flow a"to%ation
; E and D
;aintenance
;,"dit and "rveillance
ost of the big software ho"ses do not enco"rage c"sto%iation. Banks need
c"sto%iation as each bank is "ni0"e has different b"siness goals and different b"siness
%iA so c"sto%iation enhances o)erating efficienc&. e-Engineering of banking
o)erations if )receded before c"sto%iation )rovides an ideal base for eAtre%el&s"ccessf"l i%)le%entation.
(. E-anking Basi*s:
E-banking is a )rocess b& which c"sto%er )erfor% banking transaction witho"t visiting a
brick-and-%ortar instit"tion and there is a"to%ated deliver& of new and traditional
banking )rod"cts and services directl& to c"sto%ers thro"gh electronic interactive
co%%"nication channels. E-banking incl"des the s&ste%s that enable financial instit"tion
c"sto%ers individ"als or b"sinesses to access acco"nts transact b"siness or obtain
infor%ation on financial )rod"cts and services thro"gh a )"blic or )rivate networkincl"ding the nternet thro"gh vario"s intelligent electronic devices s"ch as a )ersonal
co%)"ter )ersonal digital assistant a"to%ated teller %achine kiosk
or o"ch one tele)hone.
he ter% nternet Banking or E-Banking nternet both are "sed as s"))le%ent. E-
Banking is the one of the %aor )art of E-$inancing. E-Banking is web-based Banking. n
other words E-Banking refers to the banking o)erations which is done over +orld +ide
+eb.
he advent of E-B"siness acco%)anied with technological innovations and globaliation
is constantl& )ro)elling the b"sinesses organiation to redefine their b"siness o)erations
in ter%s of val"e chain reengineering and restr"ct"ring b"siness %odels. /ikel& the
financial sector is %eta%or)hosing "nder the i%)act of co%)etitive reg"lator& and
technological forces. he banks have )"t the%selves in the +orld +ide +eb to take
advantage of the internetCs )ower and reach to co)e with the accelerating )ace of change
of b"siness environ%ent.
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The famous quote b !i"" #ates that banking is $ita" to a hea"th econom% but banks
themse"$es are not high"ights of the crucia" nature of the e"ectronic forces that are
affecting banks more than an other financia" ser$ice pro$ier group.
he nternet banking is changing the banking ind"str& and is having the %aor effects on
banking relationshi)s. Even the organ tanle& Dean +itter nternet researche%)hasied that +eb is %ore i%)ortant for retail financial services than for %an& other
ind"stries. nternet banking involves "se of nternet for deliver& of banking )rod"cts
services. t falls into fo"r %ain categories fro% /evel 1 - %ini%"% f"nctionalit& sites
that offer onl& access to de)osit acco"nt data - to /evel 4 sites - highl& so)histicated
offerings enabling integrated sales of additional )rod"cts and access to other financial
services- s"ch as invest%ent and ins"rance.
E-Banking infor%ation architect"re is %odeled as client-server architect"re. , client
o)erating thro"gh a *( linked to nternet o)ens the s)ecial E-Banking site of his bank
and then "sing a set of s)ecial sec"re n"%bers gets access to his bank acco"nts and hasthe o))ort"nit& to cons"lt the% as well as to %ake all necessar& )a&%ents and transfers
for% his )ersonal acco"nts. +hen the transaction n"%ber is eAha"sted the bank sends
hi% a new set of n"%bers for his individ"al transfer sessions. n so%e cases the bank
)rovides c"sto%ied software. he bank software )rogra% can also be "tilied offline
for eAa%)le for )re)aring the )a&%ent orders offline and then %aking the act"al order
online. he client receives all n"%bers se)aratel& %ainl& b& %ail. he bank also )rovide
clients with si%ilar facilities in its )re%ises so that clients can "se the bank e0"i)%ent
s"ch as an , or a s)ecial facilit& linked to the %ain ter%inal facilit& called "lti%at
)er%itting the% to effect the sa%e acco"nt eAa%ination )a&%ent and transfer o)erations
witho"t cons"lting the bank staff.
(./An ege "!e' t'aiti"na& anking:
One has to a))roach the branch in )erson to withdraw cash or de)osit a che0"e or
re0"est a state%ent of acco"nts. n tr"e nternet banking an& in0"ir& or transaction is
)rocessed online witho"t an& reference to the branch at an& ti%e.
*roviding nternet banking is increasingl& beco%ing a need to have than a nice to
have service. he net banking th"s now is %ore of a nor% rather than an eAce)tion in
%an& develo)ed co"ntries d"e to the fact that it is the chea)est wa& of )roviding banking
services.
Banks have traditionall& been in the forefront of harnessing technolog& to i%)rove their
)rod"cts services and efficienc&. he& have over a long ti%e been "sing electronic and
teleco%%"nication networks for delivering a wide range of val"e added )rod"cts and
services. he deliver& channels incl"de direct dial ; ") connections )rivate networks
)"blic networks etc and the devices incl"de tele)hone *ersonal (o%)"ters incl"ding the
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,"to%ated eller achines etc. +ith the )o)"larit& of *(s eas& access to nternet and
+orld +ide +eb nternet is increasingl& "sed b& banks as a channel for
receiving instr"ctions and delivering their )rod"cts and services to their c"sto%ers. his
for% of banking is generall& referred to as nternet Banking altho"gh the range of
)rod"cts and services offered b& different banks var& widel& both in their content and
so)histication.
$ro% the )ers)ective of banking )rod"cts and services being offered thro"gh nternet
nternet banking is nothing %ore than traditional banking services delivered thro"gh an
electronic co%%"nication backbone vi nternet. B"t in the )rocess it has thrown o)en
iss"es which have ra%ifications be&ond what a new deliver& channel wo"ld nor%all&
envisage and hence has co%)elled reg"lators world over to take note of this e%erging
channel.
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(.0D'i!e's "# *%ange
nfor%ation technolog& is considered as the ke& driver for the changes taking )lace
aro"nd the world. he transfor%ation fro% the traditional banking to e-banking has been
a lea)C change. he evol"tion of e-banking started fro% the "se of ,"to%atic eller
achines and tele)hone banking direct bill )a&%ent electronicf"nd transfer and the revol"tionar& online banking. he f"t"re of electronic banking
wo"ld be %ore interactive i.e. F banking. $inland is the first co"ntr& in the world to
have taken a lead in e-banking. n ndia (( Bank initiated e-banking services d"ring
166# "nder the brand na%e nfinit&C. t has been forecasted that a%ong all categories
online banking is the f"t"re of electronic financial transactions. he rise in e-co%%erce
and internet in enhancing online sec"rit& transfor%ation and sensitive infor%ation has
been the core reason for the )enetration of online banking in ever&da& life. he shift
towards the involve%ent of the c"sto%ers in the financial service with the hel) of
technolog& es)eciall& internet has hel)ed in red"cing costs of financial instit"tions as
well as clientsc"sto%ers who "se the service at an&ti%e and fro% virt"all& an&where
with access to an internet connection.
,dvantages )revio"sl& held b& large financial instit"tions have shr"nk considerabl&. he
nternet has leveled the )la&ing field and afforded o)en access to c"sto%ers in the global
%arket)lace. nternet banking is a cost-effective deliver& channel for financial
instit"tions. (ons"%ers are e%bracing the %an& benefits of nternet banking. ,ccess to
oneGs acco"nts at an&ti%e and fro% an& location via the +orld +ide +eb is a
convenience "nknown a short ti%e ago. h"s a bankGs nternet )resence transfor%s fro%
Gbro"chrewareG stat"s to Gnternet bankingG stat"s once the bank goes thro"gh a technolog&
integration effort to enable the c"sto%er to access infor%ation abo"t his or her s)ecific
acco"nt relationshi). he siA )ri%ar& drivers of nternet banking incl"des in order of
)ri%ac& are:
H %)rove c"sto%er access
H $acilitate the offering of %ore services
H ncrease c"sto%er lo&alt&
H ,ttract new c"sto%ers
H *rovide services offered b& co%)etitors
H ed"ce c"sto%er attrition
(.1 Inian anks "n ,e
ndiaCs banking sector is growing at a fast )ace. ndia has beco%e one of the %ost
)referred banking destinations in the world. he Bank credit is growing at 37I )er
ann"% and there is an ever-eA)anding %iddle class of between 257 and 377 %illion
)eo)le
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enables do"ble-digit ret"rns on %ost asset classes which is not so in a %aorit& of other
co"ntries. $oreign banks in ndia achieving a ret"rn on assets of 3I their keen
interest in eA)anding their b"sinesses is "nderstandable ; even %ore so when co%)ared
with the %easl& 1I average O, for the o) 1777 banks in the world. Banks o"tso"rce
over 95I of their infor%ation technolog& also the& are )ost)oning new technolog&
invest%ents b"t still investing in )roven technologies
he banking ind"str& in ndia is facing "n)recedented co%)etition fro% non-traditional
banking instit"tions which now offer banking and financial services over the nternet.
he dereg"lation of the banking ind"str& co")led with the e%ergence of new
technologies are enabling new co%)etitors to enter the financial services %arket 0"ickl&
and efficientl&.
ndian banks are going for the retail banking in a big wa&. 'owever %"ch is still to be
achieved. hro"gho"t the co"ntr& the nternet Banking is in the nascent stage of
develo)%ent .
n general these nternet sites offer onl& the %ost basic services. 55I are so called Gentr&
levelG sites offering little %ore than co%)an& infor%ation and basic %arketing %aterials.
Onl& 9I offer Gadvanced transactionsG s"ch as online f"nds transfer transactions cash
%anage%ent services. $oreign *rivate banks are %"ch advanced in ter%s of the
n"%ber of sites their level of develo)%ent.
(.2 E!"&+ti"n
ince the late 1667s E-Banking has develo)ed fro% virt"al insignificance to tens of
%illions of "sers worldwide 'owever E-Banking is the )rod"ct of different generations
of electronic transactions. he c"rrent web-based internet or E-Banking is the latest of
several generations of s&ste%s: ,"to%ated eller %achine *hone Banking *(
or 'o"se Banking. ,"to%ated teller %achines were the first well-known
%achines to )rovide electronic access to c"sto%ers where as in )hone banking "sers call
their bankCs co%)"ter s&ste% on their ordinar& )hone and "se the )hone ke&)ad to
)erfor% banking transactions.
*( banking s")erseded )hone banking and allowed "sers to interact with their bank b&
%eans of a co%)"ter with a dial-") %ode% connection to the )hone network. *hone and
*( banking entailed %aintenance costs associated with kee)ing ") to date with diverse
%ode%s and with avoiding )rohibitivel& co%)leA installation )roced"res. ,fter those
generations De"tsche Bank la"nched the ver& first nternet banking )roect in /atin
,%erica in 166! and (itibank has develo)ed a s)ecial Je-toolkitK across all its branches
worldwide. E-Banking "ses the web browser for the "ser interface and the nternet for
data transfer and download of software and so has a )otential for red"cing %aintenance
costs. $or "sers E-Banking )rovides c"rrent infor%ation 24-ho"rs-a-da& access to
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banking services. he )ri%ar& services )rovided b& e-banks are transferring %one&
a%ong oneCs own acco"nts )a&ing bills and checking acco"nt balances. /oans
brokering share trading service b"ndling and a host of other financial services are being
added to these )ri%ar& services E-Banking is widel& "sed in. Banks are gearing ") their
co%%"nications infrastr"ct"re to obtain a co%)etitive edge fro% E-Banking which is
fast beco%ing a realit& in ndia. E-Banking is fast beco%ing a strategic necessit& for %ost
co%%ercial banks as co%)etition increases fro% )rivate banks and ?B$s. he )rod"ct
had )riorit& over )lace banks can generate reven"e thro"gh increased acco"nt access
fees and benefit fro% )ro%otional o))ort"nit& to cross-sell )rod"cts s"ch as credit cards
and loans. D"e to the relative newness of this ra)idl& growing ind"str& banks as well as
cons"%ers had serio"s concerns abo"t the sec"rit& of nternet access to client acco"nts
which was the biggest challenge.
(ons"%ers are increasingl& looking for services the& can access fro% a single entr&
)oint. ,wareness of co%)etition has %otivated banks to %ove aggressivel& in seeking
alliances and establishing oint vent"res to %aintain their clai% to this )art of the
Eco%%erce infrastr"ct"re. /ike there are alliances in the , network 8ro") ?etwork
one& ransfer ?etwork etc. his is also creating seg%entation of networks where the
c"sto%ers of this networks so%eti%es "nable to access to othersC network. (ons"%er
behavior in banking changed )artl& as a res"lt of changes in the a%o"nt of s)are ti%e
available to individ"als. obilit& inde)endence of ti%e and )lace and fleAibilit& has
beco%e ke& words in cons"%er banking. he ke& feat"res of the nternet ; s"ch as 24
ho"r availabilit& al%ost i%%ediate access and the absence of )h&sical borders. ndeed
the nternet has been one of the ke& drivers in )ro%oting E-(o%%erce in the banking
sector. he o))ort"nities for banks in the nternet arena are varied des)ite this )lethora of o))ort"nities threats to the e-banks abo"nd. One %aor threat to banks is the Jnternet
onl&K virt"al banks. +ith @L 2 %illion one can set ") a f"ll&-f"nctional nternet Onl&
bank and )rovide )a&%ent services on the nternet.
he nternet banks serve also as gatewa&s offering identification and a"thoriation
services to a n"%ber of third )art& service )roviders. here are "ser-friendl&
o))ort"nities for cond"cting b"siness over the nternet with tele)hone co%)anies Energ&
(o%)an& taA board and other instit"tions. De%and for those services infl"ences also the
"sage rates of nternet banks. Banks for the cons"%ers and is a win-win sit"ation for the
banks and service )roviders.
t is evident that banks can obtain an advantage b& eA)loiting their eAisting E-
(o%%erce-read& infrastr"ct"re thro"gh leveraging it on the nternet b"t this o))ort"nit&
%"st be seen in the conteAt of a highl& co%)etitive ra)idl&-%oving %arket-)lace in
which new rivals are e%erging fro% %an& different directions.
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heoretical sec"rit& concerns the level of sec"rit& that is technicall& )ossibleM whereas
effective sec"rit& concerns the level of sec"rit& achieved in )ractice and is t&)icall&
lower than theoretical sec"rit&. @ser ado)tion of E-Banking is affected b& )erceived
sec"rit&. his s"))orts a view of sec"rit& as cr"cial to the overall "sabilit& of E-Banking
s&ste%s.
(.3 4"'ms "# E-anking
he following ter%s all refer to one for% or another of electronic banking: )ersonal
co%)"ter banking nternet banking virt"al banking online banking ho%e banking
re%ote electronic banking and )hone banking. *( banking and nternet or online
banking are the %ost fre0"entl& "sed designations. t sho"ld be noted however that the
ter%s "sed to describe the vario"s t&)es of electronic banking are often "sed
interchangeabl&.
C"'5"'ate e - Banking
cor)orate e-banking is a co%)rehensive cor)orate and s%all b"siness banking sol"tion
)roviding a single "nified view of cor)orate banking relationshi)s across asset and
liabilit& )rod"cts li%its trade finance and cash %anage%ent. t is designed to s"))ort
%"lti)le channels incl"ding the nternet and %obile and can be interfaced with dis)arate
host s&ste%s and third-)art& a))lications. his e%)owers banks to )rovide their
cor)orate c"sto%ers an&ti%e an&where access to real-ti%e consolidated infor%ation
he sol"tion is b"ilt on new-generation ind"str& standard technologies N2EE and .?E.
Ke6 #eat+'es:
• ,cco"nts and ransfers
• Electronic nvoice *resent%ent *a&%ent
• *a&%ents
• (ollections anage%ent
• /i0"idit& anage%ent
• econciliation e)orting
• rade $inance
C"ns+me' e-anking
(ons"%er e-banking sol"tion is a )roven nternet banking and %obile banking sol"tion
for retail banking c"sto%ers. B"ilt on new-generation technolog& it )rovides a single
"nified view of the c"sto%erGs %an& relationshi)s with the bank. he sol"tion )rovides
high fleAibilit& for c"sto%iation and rob"st sec"rit& feat"res.
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his sol"tion can be interfaced with an& core banking sol"tion directl& or thro"gh an
ind"str& standard %iddleware. t )rovides banking c"sto%ers real ti%e access to their
relationshi)s with the bank s"ch as acco"nt in0"iries f"nd transfers credit cards %"t"al
f"nds )a&%ents and re%ittances. t enables the% to %ake )a&%ents to individ"als or
instit"tions and other general )a&%ents online. (ons"%er nternet Banking with its
abilit& to reach each and ever& nook and crann& of the world holds great i%)ortance for a
nation like ndia where conventional Banking services are o"t of reach for a large
)ro)ortion of the %asses. B"t to %ake it a s"ccess it re0"ires %ore than "st an ade0"ate
internet enabling infrastr"ct"re
Ke6 #eat+'es:
• (ore od"le
• *a&%ents od"le
• (redit (ard and "t"al $"nd od"les
• Electronic Bill *a&%ent and *resent%ent od"le
• ,lerts od"le
• ec"rit& $eat"res
• obile Banking
o date %ore banks have established an advertising )resence on the nternet )ri%aril&
in the for% of infor%ational or interactive web sitesthan have created transactional web
sites. 'owever a n"%ber of Banks that do not &et offer transactional nternet banking
services have indicated on their web sites that the& will offer s"ch banking activities in
the f"t"re.
,ltho"gh nternet banks offer %an& of the sa%e services as do traditional brick-and-
%ortar Banks anal&sts view nternet banking as a %eans of retaining increasingl&
so)histicated c"sto%ers of develo)ing a new c"sto%er base and of ca)t"ring a greater
share of de)ositor assets. , t&)ical nternet bank site s)ecifies the t&)es of transactions
offered and )rovides infor%ation abo"t acco"nt sec"rit&.
Beca"se nternet banks generall& have lower o)erational and transactional costs than do
traditional brick-and-%ortar banks the& are often able to offer low-cost checking and
high-&ield (ertificates of de)osit. nternet banking is not li%ited to a )h&sical siteM so%e
nternet banks eAist witho"t )h&sical branches for eAa%)le elebank and Banknet . $"rther in so%e cases web banks are not restricted to
cond"cting transactions within national borders and have the abilit& to %ake transactions
involving large a%o"nts of assets instantaneo"sl&.
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E-Banking C"m5etiti!eness
E-Banking is develo)ing grad"all& and it is getting acce)tance globall&. B"t whether this
field is l"crative for entr& can be "dged b& ind"str& and co%)etitive anal&sis. /ike other
ind"str& *orterCs $ive $orces odel of (o%)etition can also be a))lied to "nderstand E-
Banking co%)etitiveness.
Rivalry among Competing Parties
,s there is no single internet onl& bank eAist in this world the c"rrent rivalr& a%ong the
co%)etitor or banks in the banking ind"str& sho"ld be considered. Banking instit"tions
are co"ntering their co%)etitors b& leveraging E-(o%%erce technologies and vario"s
service offerings online this is a %aor shift fro% the earl& da&s of Electronic $"nds
ransfer when large organiations introd"ced electronic banking to si%)lif& the
%anage%ent of their salar& and )a&roll )roble%s.
Banks are leveraging it as a distrib"tion channel to offer co%)leA )rod"cts at the sa%e
0"alit& the& can )rovide fro% their )h&sical branches at a lower cost to %ore )otential
c"sto%ers witho"t bo"ndaries. E-Banking is "sed to a"g%ent their c"rrent val"e chain
offering new )rod"ct and co%)ete for the c"sto%ers.
New Entrants
,t )resent the entr& barriers to nternet banking a))ear to be %"ch higher for new
entrants than was the case d"ring the earl& da&s of this t&)e of banking. he barriers ste%
fro% c"sto%er attit"des and the ver& nat"re of banking services and )rod"cts. he
traditional banks with a strong c"sto%er base have a co%)etitive advantage over newco%ers.
Buyers
he nternet has leveled the )la&ing field: the bargaining )ower of cons"%ers is
increasing switching costs are beco%ing lower
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. E-BANKING COMPONENTS
.( E-Banking St'ateg6
everal %odel of E-B"siness were tried b& different banks all over the world to get the%
involved in the E-Banking vicinit&. he %ost "sed E-B"siness %odel were Internet 'n"% !rick-an-("ick or ("ick-an-Mortar) 'owever nternet Onl&C %odel failed to s"rvive.
ec"rit& $irst ?et Bank which was for%ed in 166! in the @ and clai%s to be
the first nternet-onl& bank in the world. B"t it was ac0"ired b& the o&al Bank of
(anada in 1669 s"ggesting that c"sto%ers %a& still want the co%fort of a )h&sical
)resence. he )resent trend is Brick and (lickC or (lick and ortarC where banks serve
their c"sto%ers thro"gh internet having )h&sical o)erations si%"ltaneo"sl&. *rogress in
infor%ation technolog& has red"ced trans)ortation costs transaction cost and th"s
s"ggests that the nternet enabled banks to offer low-cost high val"e-added financial
services. ,ltho"gh )rice incentives can )la& significant role in getting c"sto%ers online
the service needs to be based on 0"alit& rather than )rice onl&. Develo)ing technological
sol"tions sho"ld was not done with a )rod"ct or line of b"siness in foc"s b"t with a
c"sto%er relationshi) foc"s with integrated deliver& of )rod"cts and services. "ccess or
fail"re in nternet banking is greatl& deter%ined b& the integration of technolog&
infrastr"ct"re with the b"siness )rocesses.
E-Banking 7"'& 7ie
ince its ince)tion nternet banking has eA)erienced strong and s"stained growth. +orld
Bank re)ort on lea)frogging in e-finance )ointed o"t that the three co"ntries with
i%)ressive )rogress in infor%ation technolog& in this sense are Estonia e)"blic of =orea and Brail. (reation of the worldCs leading electronic banking s&ste%s has been
done at a re%arkabl& low cost co%)ared to other world-class internet banks
he share of @nited tates ho"seholds "sing nternet banking will increase to 55 billion
"sers b& 2717. 8rowth in this area has been driven b& traditional banks which have "sed
the online channel to generate c"sto%er lo&alt& and i%)rove their o)erating %argins.
,ll banks offering E-Banking also offer sec"rit& for transactions "sing firewalls vir"s
)rotection 129 bit encr&)tion verification b& %eans of digital certificate and
state li%its to c"sto%er liabilit& for "na"thoried "se of access codes. n ,sia one of the%ost i%)ressive records has been achieved b& the e)"blic of =orea. nternet banking in
that co"ntr& has increased at a ra)id )ace. he e)"blic of =orea is also leading in online
brokerage and in %obile banking. n o"th-East ,sia nternet banking is also develo)ing
ra)idl& in hailand ala&sia and inga)ore and to a lesser eAtent in the *hili))ines.
,)art fro% ?orth and o"th ,frica the "b aharan ,frica is the region that is serio"sl&
lagging behind in nternet banking altho"gh it is giving to the rest of the world the good
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eAa%)le of %icrofinance develo)%ents. Banking is likel& to be a significant co%)onent
of the )rod"ct deliver& and c"sto%er strateg& of the strategic %arketing )lans of c"tting-
edge $s in the f"t"re.
. 4a*t"'s in#&+en*ing e-anking s6stem
E-banking s&ste%s can var& significantl& in their config"ration de)ending on a n"%ber
of factors. $inancial instit"tions sho"ld choose their e-banking s&ste% config"ration
incl"ding o"tso"rcing relationshi)s based on fo"r factors:
• trategic obectives for e-bankingM
• co)e scale and co%)leAit& of e0"i)%ent s&ste%s and activities
• echnolog& eA)ertise
• ec"rit& and internal control re0"ire%ents.
./ "st Entities
$inancial instit"tions %a& choose to s"))ort their e-banking services internall&.
,lternativel& financial instit"tions can o"tso"rce an& as)ect of their e-banking s&ste%s to
third )arties. he following entities co"ld )rovide or host e-banking-related services for financial instit"tions:
• ,nother financial instit"tion
• nternet service )rovider
• nternet banking software vendor or )rocessor
• (ore banking vendor or )rocessor
•
anaged sec"rit& service )rovider
• Bill )a&%ent )rovider
• (redit b"rea"
• (redit scoring co%)an&.
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.0 C"m5"nents an P'"*esses
E-banking s&ste%s rel& on a n"%ber of co%%on co%)onents or )rocesses. he following
list incl"des %an& of the )otential co%)onents and )rocesses seen in a t&)ical instit"tion:
• +ebsite design and hosting
• $irewall config"ration and %anage%ent
• ntr"sion detection s&ste% or D
• ?etwork ad%inistration
• ec"rit& %anage%ent
•
nternet banking server
• E-co%%erce a))lications
• nternal network servers
• (ore )rocessing s&ste%
• *rogra%%ing s"))ort
• ,"to%ated decision s"))ort s&ste%s
hese co%)onents work together to deliver e-banking services. Each co%)onent
re)resents a control )oint to consider. hro"gh a co%bination of internal and o"tso"rced
sol"tions %anage%ent has %an& alternatives when deter%ining the overall s&ste%
config"ration for the vario"s co%)onents of an e-banking s&ste%. One or %ore
technolog& service )roviders can host the e-banking a))lication and n"%ero"s network
co%)onents as ill"strated in the following diagra%. n this config"ration the instit"tionCs
service )rovider hosts the instit"tionCs website nternet banking server firewall and
intr"sion detection s&ste%. +hile the instit"tion does not have to %anage the dail&
ad%inistration of these co%)onent s&ste%s its %anage%ent and board re%ain
res)onsible for the content )erfor%ance and sec"rit& of the e-banking s&ste%.
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PcloseQ
4ig+'e (: T%i'-Pa't6 P'"!ie' "ste E-Banking Diag'am
his diagra% ill"strates the transaction flow for one )ossible config"ration where the
bank relies on a technolog& service )rovider to host its nternet banking a))lication.
nternet banking c"sto%er sends an e-banking transaction thro"gh their nternet
ervice *rovider via a )hone wireless or broadband connection.
he c"sto%erCs * ro"tes the transaction thro"gh the nternet and sends it to the e-
banking service )roviderGs * which ro"tes it to the )rovider.
he transaction enters the )roviderGs network thro"gh a ro"ter which directs the e-
banking transaction thro"gh a firewall to the a))lication r"nning on the nternet banking
server.
he website server and nternet banking server %a& have host-based intr"sion
detection s&ste% software %onitoring the server and its files to )rovide alerts of
)otential "na"thoried %odifications.
?etwork D software %a& reside at different )oints within the network to anal&e
the %essage for )otential attack characteristics that s"ggest an intr"sion atte%)t.
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he nternet banking a))lication )rocesses the transaction against acco"nt balance
data thro"gh a real ti%e connection to the core banking s&ste% or a database of acco"nt
balance data which is ")dated )eriodicall& fro% the core banking s&ste%.
he nternet banking server has a firewall filtering nternet traffic fro% its internal
network.
/. E-BANKING SUPPORT SERVICES
n addition to traditional banking )rod"cts and services financial instit"tions can )rovide
a variet& of services that have been designed or ada)ted to s"))ort e-co%%erce.anage%ent sho"ld "nderstand these services and the risks the& )ose to the instit"tion.
C"mm"n E-Banking Se'!i*es
o%e of the co%%on retail and wholesale e-banking services offered b& financial
instit"tions are:
etail ervices
1. ,cco"nt %anage%ent
2. Bill )a&%ent and )resent%ent
3. ?ew acco"nt o)ening
4. (ons"%er wire transfers
5. nvest%entBrokerage services
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!. /oan a))lication and a))roval
+holesale ervices
1. ,cco"nt %anage%ent
2. (ash %anage%ent
3. %all b"siness loan a))lications a))rovals or advances
4. (o%%ercial wire transfers
5. B"siness-to-b"siness )a&%ents
E%)lo&ee benefits)ension ad%inistration
/.( 7e&inking
, large n"%ber of financial instit"tions %aintain sites on the +orld +ide +eb. o%e
websites are strictl& infor%ational while others also offer c"sto%ers the abilit& to
)erfor% financial transactions s"ch as )a&ing bills or transferring f"nds between
acco"nts.
Firt"all& ever& website contains Jweblinks.K , weblink is a word )hrase or i%age on a
web)age that contains coding that will trans)ort the viewer to a different )art of the
website or a co%)letel& different website b& "st clicking the %o"se. +hile weblinks are
a convenient and acce)ted tool in website design their "se can )resent certain risks.
8enerall& the )ri%ar& risk )osed b& weblinking is that viewers can beco%e conf"sedabo"t whose website the& are viewing and who is res)onsible for the infor%ation
)rod"cts and services available thro"gh that website. here are a variet& of risk
%anage%ent techni0"es instit"tions sho"ld consider "sing to %itigate these risks. hese
risk %anage%ent techni0"es are for those instit"tions that develo) and %aintain their own
websites as well as instit"tions that "se third-)art& service )roviders for this f"nction.
he agencies have iss"ed g"idance on weblinking that )rovides details on risks and risk
%anage%ent techni0"es financial instit"tions sho"ld consider.
/. A**"+nt Agg'egati"n
,cco"nt aggregation is a service that gathers infor%ation fro% %an& websites )resents
that infor%ation to the c"sto%er in a consolidated for%at and in so%e cases %a& allow
the c"sto%er to initiate activit& on the aggregated acco"nts. he infor%ation gathered or
aggregated can range fro% )"blicl& available infor%ation to )ersonal acco"nt
infor%ation . ,ggregation services can
i%)rove c"sto%er convenience b& avoiding %"lti)le log-ins and )roviding access to tools
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that hel) c"sto%ers anal&e and %anage their vario"s acco"nt )ortfolios. o%e
aggregators "se the c"sto%er-)rovided "ser Ds and )asswords to sign in as the c"sto%er.
Once the c"sto%erCs acco"nt is accessed the aggregator co)ies the )ersonal acco"nt
infor%ation fro% the website for re)resentation on the aggregatorCs site . Other aggregators "se direct data-feed arrange%ents with website o)erators or
other fir%s to obtain the c"sto%erCs infor%ation. 8enerall& direct data feeds are tho"ght
to )rovide greater legal )rotection to the aggregator than does screen scra)ing.
/./ E&e*t'"ni* A+t%enti*ati"n
eliable c"sto%er a"thentication is i%)erative for E-banking. Effective a"thentication
can hel) banks red"ce fra"d re)"tation risk disclos"re of c"sto%er infor%ation and
)ro%ote the legal enforceabilit& of their electronic agree%ents verif&ing the identities of
c"sto%ers and a"thoriing e-banking activities are integral )arts of e-banking financial
services. ince traditional )a)er-based and in-)erson identit& a"thentication %ethodsred"ce the s)eed and efficienc& of electronic transactions financial instit"tions have
ado)ted alternative a"thentication %ethods incl"ding:
ethods to a"thenticate c"sto%ers:
• *asswords *?
• Digital certificates *=
• *h&sical devices s"ch as tokens
• Bio%etric identifiers
he a"thentication %ethods listed above var& in the level of sec"rit& and reliabilit& the&
)rovide in the cost and co%)leAit& of their "nderl&ing infrastr"ct"res. ,s s"ch the choice
of which techni0"e to "se sho"ld be co%%ens"rate with the risks in the )rod"cts and
services for which the& control access. he Electronic ignat"res in 8lobal and ?ational
(o%%erce ,ct establishes so%e "nifor% federal r"les concerning the legal
stat"s of electronic signat"res and records in co%%ercial and cons"%er transactions so as
to )rovide %ore legal certaint& and )ro%ote the growth of electronic co%%erce. he
develo)%ent of sec"re digital signat"res contin"es to evolve with so%e financialinstit"tions either acting as the certification a"thorit& for digital signat"res or )roviding
re)ositor& services for digital certificates.
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4ig+'e : Sna5s%"t s%",ing &"gin 5age "# D4C ank9s e-anking ,esite
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4ig+'e /: D4C ank9s ,e5age s%",ing a**"+nt etai&s
/.0 7esite "sting
o%e financial instit"tions host websites for both the%selves as well as for other
b"sinesses. $inancial instit"tions that host a b"siness c"sto%erCs website "s"all& store or
arrange for the storage of the electronic files that %ake ") the website. hese files arestored on one or %ore servers that %a& be located on the hosting financial instit"tionCs
)re%ises. +ebsite hosting services re0"ire strong skills in networking sec"rit& and
)rogra%%ing. he technolog& and software change ra)idl&. nstit"tions develo)ing
websites sho"ld %onitor the need to ado)t new intero)erabilit& standards and )rotocols
s"ch as EAtensible ark-@) /ang"age to facilitate data eAchange a%ong the
diverse )o)"lation of nternet "sers.
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/.1 Pa6ments #"' E-C"mme'*e
an& b"sinesses acce)t vario"s for%s of electronic )a&%ents for their )rod"cts and
services. $inancial instit"tions )la& an i%)ortant role in electronic )a&%ent s&ste%s b&
creating and distrib"ting a variet& of electronic )a&%ent instr"%ents acce)ting a si%ilar
variet& of instr"%ents )rocessing those )a&%ents and )artici)ating in clearing and
settle%ent s&ste%s. 'owever increasingl& financial instit"tions are co%)eting with third
)arties to )rovide s"))ort services for e-co%%erce )a&%ent s&ste%s. ,%ong the
electronic )a&%ents %echanis%s that financial instit"tions )rovide for e-co%%erce are
a"to%ated clearing ho"se
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1. $inancial instit"tions that do not )rovide bill )a&%ent services b"t %a& direct
c"sto%ers to select fro% several "naffiliated bill )a&%ent )roviders.
-(a"tion c"sto%ers regarding sec"rit& and )rivac& iss"es thro"gh the "se of on-line
disclos"res or %ore conservativel& e-banking agree%ents
2. $inancial instit"tions that rel& on a third-)art& bill )a&%ent )rovider incl"ding nternet
banking )roviders that s"bcontract to third )arties.
-et dollar and vol"%e thresholds and review bill )a&%ent transactions for s"s)icio"s
activit&
-8ain inde)endent a"dit ass"rance over the bill )a&%ent )roviderCs )rocessing controls.
-estrict e%)lo&eesC ad%inistrative access to ens"re that the internal controls li%iting
their ca)abilities to originate %odif& or delete bill )a&%ent transactions are at least asstrong as those a))licable to the "nderl&ing retail )a&%ent s&ste% "lti%atel& trans%itting
the transaction.
-estrict b& vendor contract and identif& the "se of an& s"bcontractors associated with
the bill )a&%ent a))lication to ens"re ade0"ate oversight of "nderl&ing bill )a&%ent
s&ste% )erfor%ance and availabilit&.
-Eval"ate the ade0"ac& of a"thentication %ethods given the higher risk associated with
f"nds transfer ca)abilities rather than with basic acco"nt access
3. $inancial instit"tions that "se third-)art& software to host a bill )a&%ent a))lication
internall&.
-Deter%ine the eAtent of an& inde)endent assess%ents or certification of the sec"rit& of
a))lication so"rce code.
-Ens"re software is ade0"atel& tested )rior to installation on the live s&ste%
-Ens"re vendor access for software %aintenance is controlled and %onitored.
4. $inancial instit"tions that develo) %aintain and host their own bill )a&%ent s&ste%
$inancial instit"tions can offer bill )a&%ent as a stand-alone service or in co%bination
with bill )resent%ent. Bill )resent%ent arrange%ents )er%it a b"siness to s"b%it a
c"sto%erCs bill in electronic for% to the c"sto%erCs financial instit"tion. ("sto%ers can
view their bills b& clicking on links on their acco"ntCs e-banking screen or %en". ,fter
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viewing a bill the c"sto%er can initiate bill )a&%ent instr"ctions or elect to )a& the bill
thro"gh a different )a&%ent channel.
n addition so%e b"sinesses have beg"n offering electronic bill )resent%ent directl&
fro% their own websites rather than thro"gh links on the e-banking screens of a financial
instit"tion. @nder s"ch arrange%ents c"sto%ers can log on to the b"sinessCs website to
view their )eriodic bills. hen if so desired the& can electronicall& a"thorie the
b"siness to JtakeK the )a&%ent fro% their acco"nt. he )a&%ent then occ"rs as an ,('
debit originated b& the b"sinessCs financial instit"tion as co%)ared to the ,(' credit
originated b& the c"sto%erCs financial instit"tion in the bill )a&%ent scenario described
above. nstit"tions sho"ld ens"re )ro)er a))roval of b"sinesses allowed to "se ,('
)a&%ent technolog& to initiate )a&%ents fro% c"sto%er acco"nts.
(ash %anage%ent a))lications wo"ld incl"de the sa%e control considerations described
above b"t the instit"tion sho"ld consider additional controls beca"se of the higher risk
associated with co%%ercial transactions. he ade0"ac& of a"thentication %ethods
beco%es a higher )riorit& and re0"ires greater ass"rance d"e to the larger average dollar
sie of transactions. nstit"tions sho"ld also establish additional controls to ens"re
binding agree%ents ; consistent with an& eAisting ,(' or wire transfer agree%ents ;
eAist with co%%ercial c"sto%ers. ,dditionall& cash %anage%ent s&ste%s sho"ld )rovide
ade0"ate sec"rit& ad%inistration ca)abilities to enable the b"siness owners to restrict
access rights and dollar li%its associated with %"lti)le-"ser access to their acco"nts.
/.1. Pe's"n-t"-Pe's"n Pa6ments
Electronic )erson-to-)erson )a&%ents also known as e-%ail %one& )er%it cons"%ers to
send J%one&K to an& )erson or b"siness with an e-%ail address. @nder this scenario a
cons"%er electronicall& instr"cts the )erson-to-)erson )a&%ent service to transfer f"nds
to another individ"al. he )a&%ent service then sends an e-%ail notif&ing the individ"al
that the f"nds are available and infor%s hi% or her of the %ethods available to access the
f"nds incl"ding re0"esting a check transferring the f"nds to an acco"nt at an ins"red
financial instit"tion or retrans%itting the f"nds to so%eone else. *erson-to-)erson
)a&%ents are t&)icall& f"nded b& credit card charges or b& an ,(' transfer fro% the
cons"%erCs acco"nt at a financial instit"tion. ince neither the )a&ee nor the )a&er in the
transaction has to have an acco"nt with the )a&%ent service s"ch services %a& beoffered b& an ins"red financial instit"tion b"t are fre0"entl& offered b& other b"sinesses
as well.
/.2 7i'e&ess E-Banking
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+ireless banking is a deliver& channel that can eAtend the reach and enhance the
convenience of nternet banking )rod"cts and services. +ireless banking occ"rs when
c"sto%ers access a financial instit"tionGs network "sing cell"lar )hones )agers and
)ersonal digital assistants thro"gh teleco%%"nication co%)aniesC
wireless networks. +ireless banking services in the @nited tates t&)icall& s"))le%ent a
financial instit"tionGs e-banking )rod"cts and services.
+ireless devices have li%itations that increase the sec"rit& risks of wireless-based
transactions and that %a& adversel& affect c"sto%er acce)tance rates. Device li%itations
incl"de red"ced )rocessing s)eeds li%ited batter& life s%aller screen sies different
data entr& for%ats and li%ited ca)abilities to transfer stored records. hese li%itations
co%bine to %ake the %ost recognied nternet lang"age '&)erteAt ark") /ang"age
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)rocesses tools eA)ertise and testing. nstit"tions sho"ld deter%ine the a))ro)riate level
of sec"rit& controls based on their assess%ent of the sensitivit& of the infor%ation to the
c"sto%er and to the instit"tion and on the instit"tionCs established risk tolerance level.
0. CREDIT RISK
8enerall& a financial instit"tionCs credit risk is not increased b& the %ere fact that a loan
is originated thro"gh an e-banking channel. 'owever %anage%ent sho"ld consider
additional )reca"tions when originating and a))roving loans electronicall& incl"ding
ass"ring %anage%ent infor%ation s&ste%s effectivel& track the )erfor%ance of )ortfolios
originated thro"gh e-banking channels. he following as)ects of on-line loan origination
and a))roval tend to %ake risk %anage%ent of the lending )rocess %ore challenging. f
not )ro)erl& %anaged these as)ects can significantl& increase credit risk.
Ferif&ing the c"sto%erCs identit& for on-line credit a))lications and eAec"ting anenforceable contractM
onitoring and controlling the growth )ricing "nderwriting standards and ongoing
credit 0"alit& of loans originated thro"gh e-banking channelsM
onitoring and oversight of third-)arties doing b"siness as agents or on behalf of the
financial instit"tion M
Fal"ing collateral and )erfecting liens over a )otentiall& wider geogra)hic areaM
(ollecting loans fro% individ"als over a )otentiall& wider geogra)hic areaM and
onitoring an& increased vol"%e of and )ossible concentration in o"t-of-area
lending.
0./ ;I INTEREST RATE> PRICEMARKET RISKS
$"nding and invest%ent-related risks co"ld increase with an instit"tionCs e-banking
initiatives de)ending on the volatilit& and )ricing of the ac0"ired de)osits. he nternet
)rovides instit"tions with the abilit& to %arket their )rod"cts and services globall&.nternet-based advertising )rogra%s can effectivel& %atch &ield-foc"sed investors with
)otentiall& high-&ielding de)osits. B"t nternet-originated de)osits have the )otential to
attract c"sto%ers who foc"s eAcl"sivel& on rates and %a& )rovide a f"nding so"rce with
risk characteristics si%ilar to brokered de)osits. ,n instit"tion can control this )otential
volatilit& and eA)anded geogra)hic reach thro"gh its de)osit contract and acco"nt
o)ening )ractices which %ight involve face-to-face %eetings or the eAchange of )a)er
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corres)ondence. he instit"tion sho"ld %odif& its )olicies as necessar& to address the
following e-banking f"nding iss"es:
*otential increase in de)endence on brokered f"nds or other highl& rate-sensitive
de)osits
*otential ac0"isition of f"nds fro% %arkets where the instit"tion is not licensed to
engage in banking )artic"larl& if the instit"tion does not establish disclose and
enforce geogra)hic restrictionsM
*otential i%)act of loan or de)osit growth fro% an eA)anded nternet %arket
incl"ding the i%)act of s"ch growth on ca)ital ratiosM and
*otential increase in volatilit& of f"nds sho"ld e-banking sec"rit& )roble%s
negativel& i%)act c"sto%er confidence or the %arketCs )erce)tion of the instit"tion.
0.0 COMP;IANCE;EGA; RISK
(o%)liance and legal iss"es arise o"t of the ra)id growth in "sage of e-banking and the
differences between electronic and )a)er-based )rocesses. E-banking is a new deliver&
channel where the laws and r"les governing the electronic deliver& of certain financial
instit"tion )rod"cts or services %a& be a%big"o"s or still evolving. )ecific reg"lator&
and legal challenges incl"de:
@ncertaint& over legal "risdictions and which stateCs or co"ntr&Cs laws govern a
s)ecific e-banking transaction
Deliver& of credit and de)osit-related disclos"resnotices as re0"ired b& law or
reg"lation
etention of re0"ired co%)liance doc"%entation for on-line advertising
a))lications state%ents disclos"res and noticesM and
Establish%ent of legall& binding electronic agree%ents.
/aws and reg"lations governing cons"%er transactions re0"ire s)ecific t&)es of
disclos"res notices or record kee)ing re0"ire%ents. hese re0"ire%ents also a))l& to e-
banking and federal banking agencies contin"e to ")date cons"%er laws and reg"lations
to reflect the i%)act of e-banking and on-line c"sto%er relationshi)s. o%e of the legal
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re0"ire%ents and reg"lator& g"idance that fre0"entl& a))l& to e-banking )rod"cts and
services incl"de:
olicitation collection and re)orting of govern%ent %onitoring infor%ation on
a))lications and loans as re0"ired b& E0"al (redit O))ort"nit& ,ct
and $air (redit e)orting ,ct reg"lations.
nstit"tions that offer e-banking services both infor%ational and transactional ass"%e a
higher level of co%)liance risk beca"se of the changing nat"re of the technolog& the
s)eed at which errors can be re)licated and the fre0"enc& of reg"lator& changes to
address e-banking iss"es. he )otential for violations is f"rther heightened b& the need to
ens"re consistenc& between )a)er and electronic advertise%ents disclos"res and notices.
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0.1 STRATEGIC RISK
, financial instit"tionCs board and %anage%ent sho"ld "nderstand the risks associated
with e-banking services and eval"ate the res"lting risk %anage%ent costs against the
)otential ret"rn on invest%ent )rior to offering e-banking services. *oor e-banking
)lanning and invest%ent decisions can increase a financial instit"tionCs strategic risk.
Earl& ado)ters of new e-banking services can establish the%selves as innovators who
antici)ate the needs of their c"sto%ers b"t %a& do so b& inc"rring higher costs and
increased co%)leAit& in their o)erations. (onversel& late ado)ters %a& be able to avoid
the higher eA)ense and added co%)leAit& b"t do so at the risk of not %eeting c"sto%er
de%and for additional )rod"cts and services. n %anaging the strategic risk associated
with e-banking services financial instit"tions sho"ld develo) clearl& defined e-banking
obectives b& which the instit"tion can eval"ate the s"ccess of its e-banking strateg&. n
)artic"lar financial instit"tions sho"ld )a& attention to the following:
,de0"ac& of %anage%ent infor%ation s&ste%s to track e-banking "sage and
)rofitabilit&M
(osts involved in %onitoring e-banking activities or costs involved in overseeing e-
banking vendors and technolog& service )rovidersM
Design deliver& and )ricing of services ade0"ate to generate s"fficient c"sto%er
de%andM
etention of electronic loan agree%ents and other electronic contracts in a for%at
that will be ad%issible and enforceable in litigationM
(osts and availabilit& of staff to )rovide technical s"))ort for interchanges involving
%"lti)le o)erating s&ste%s web browsers and co%%"nication devicesM
(o%)etition fro% other e-banking )rovidersM and
,de0"ac& of technical o)erational co%)liance or %arketing s"))ort for e-banking
)rod"cts and services.
0.2 REPUTATION RISK
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,n instit"tionCs decision to offer e-banking services es)eciall& the %ore co%)leA
transactional services significantl& increases its level of re)"tation risk. o%e of the
wa&s in which e-banking can infl"ence an instit"tionCs re)"tation incl"de:
/oss of tr"st d"e to "na"thoried activit& on c"sto%er acco"nts
Disclos"re or theft of confidential c"sto%er infor%ation to "na"thoried )arties
$ail"re to deliver on %arketing clai%s
$ail"re to )rovide reliable service d"e to the fre0"enc& or d"ration of service
disr")tions
("sto%er co%)laints abo"t the diffic"lt& in "sing e-banking services and the
inabilit& of the instit"tionCs hel) desk to resolve )roble%s
(onf"sion between services )rovided b& the financial instit"tion and services
)rovided b& other b"sinesses linked fro% the website.
1. RISK MANAGEMENT
he Basel (o%%ittee on Banking ")ervision eA)ects s"ch risks to be recognied
addressed and %anaged b& banking instit"tions in a )r"dent %anner according to the
f"nda%ental characteristics and challenges of e-banking services. hese characteristics
incl"de the "n)recedented s)eed of change related to technological and c"sto%er service
innovation the "bi0"ito"s and global nat"re of o)en electronic networks the integration
of e-banking a))lications with legac& co%)"ter s&ste%s and the increasing de)endence
of banks on third )arties that )rovide the necessar& infor%ation technolog&. +hile not
creating inherentl& new risks the (o%%ittee noted that these characteristics increased
and %odified so%e of the traditional risks associated with banking activities in )artic"lar
strategic o)erational and legal and re)"tation risks thereb& infl"encing the overall risk
)rofile of banking.
Based on these concl"sions the (o%%ittee considers that while eAisting risk
%anage%ent )rinci)les re%ain a))licable to e-banking activities s"ch )rinci)les %"st be
tailored ada)ted and in so%e cases eA)anded to address the s)ecific risk %anage%ent
challenges created b& the characteristics of e-banking activities. etting detailed risk
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%anage%ent re0"ire%ents in the area of e-banking %ight be co"nter-)rod"ctive if onl&
beca"se these wo"ld be likel& to beco%e ra)idl& o"tdated beca"se of the s)eed of change
related to technological and c"sto%er service innovation. he (o%%ittee has therefore
)referred to eA)ress s")ervisor& eA)ectations and g"idance in the for% of isk
anage%ent *rinci)les in order to )ro%ote safet& and so"ndness for ebanking activities
while )reserving the necessar& fleAibilit& in i%)le%entation that derives in )art fro% the
s)eed of change in this area.
he isk anage%ent *rinci)les fall into three broad and often overla))ing categories
of iss"es that are gro")ed to )rovide clarit&: Board and anage%ent OversightM ec"rit&
(ontrolsM and /egal and e)"tation isk anage%ent
5.1Board and Management Oversight:
Prini!"es:
1. Effective %anage%ent oversight of e-banking activities: he Board of Directors and
senior %anage%ent sho"ld establish effective %anage%ent oversight over the risks
associated with e-banking activities incl"ding the establish%ent of s)ecific
acco"ntabilit& )olicies and controls to %anage these risks.
2. Establish%ent of a co%)rehensive sec"rit& control )rocess: he Board of Directors and
senior %anage%ent sho"ld review and a))rove the ke& as)ects of the bankGs sec"rit&
control )rocess.
3. (o%)rehensive d"e diligence and %anage%ent oversight )rocess for o"tso"rcing
relationshi)s and other third-)art& de)endencies: he Board of Directors and senior %anage%ent sho"ld establish a co%)rehensive and ongoing d"e diligence and oversight
)rocess for %anaging the bankGs o"tso"rcing relationshi)s and other third-)art&
de)endencies s"))orting ebanking.
Beca"se the Board of Directors and senior %anage%ent are res)onsible for develo)ingthe instit"tionCs b"siness strateg& and establishing an effective %anage%ent oversightover risks the& are eA)ected to take an eA)licit infor%ed and doc"%ented strategicdecision as to whether and how the bank is to )rovide ebanking services. he initialdecision sho"ld incl"de the s)ecific acco"ntabilities )olicies and controls to addressrisks incl"ding those arising in a cross-border conteAt. Effective %anage%ent oversight
is eA)ected to enco%)ass the review and a))roval of the ke& as)ects of the bankCssec"rit& control )rocess s"ch as the develo)%ent and %aintenance of a sec"rit& controlinfrastr"ct"re that )ro)erl& safeg"ards e-banking s&ste%s and data fro% both internal andeAternal threats. t also sho"ld incl"de a co%)rehensive )rocess for %anaging risksassociated with increased co%)leAit& of and increasing reliance on o"tso"rcingrelationshi)s and third-)art& de)endencies to )erfor% critical e-banking f"nctions
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1.SECURIT=
Ke6 E&ements "# Se*+'it6 P'"g'am
eviewing )h&sical and logical sec"rit&:
a. eview intr"sion detection and res)onse ca)abilities to ens"re that
intr"sions will be detected and controlled b. eek necessar& eA)ertise and training as needed to )rotect )h&sical
locations and networks fro% "na"thoried access
c. aintain knowledge of c"rrent threats facing the bank and the
v"lnerabilities to s&ste%s
d. ,ssess firewalls and intr"sion detection )rogra%s at both )ri%ar& and
back-") sites to %ake s"re the& are %aintained at c"rrent ind"str& best
)ractice levels.
e. Ferif& the identit& of new e%)lo&ees contractors or third )arties
accessing &o"r s&ste%s or facilities. f warranted )erfor% backgro"nd
checks. eview s"ccession )lans for ke& e%)lo&ees and delegations ofa"thorit& in the event of a crisis.
f. Eval"ate whether )h&sical access to all facilities is ade0"ate.
g. +ork with service )rovider and other relevant c"sto%ers to ens"re
effective logical and )h&sical sec"rit& controls.
ec"rit& ss"es in E-Banking
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$irewall )rotection
nternet banking and )a&%ent s&ste%s %a& allow for new wa&s to cond"ct illegal and
fra"d"lent activities ,ccording to 2771 $B( s"rve& #7I re)orted that the nternet is
the )oint of c&ber attacks. Banks are re0"ired to establish ad%inistrative technical
)h&sical safeg"ards to )rotect the )rivac& of c"sto%ersC non)"blic c"sto%er records and
infor%ation
he sec"rit& of an nternet banking %odel %"st be addressed at three levels. he first
concern is the sec"rit& of c"sto%er nfor%ation as it is sent fro% the c"sto%erGs *( to the
+eb server. he second area concerns the sec"rit& of the environ%ent in which the
nternet banking server and c"sto%er infor%ation database reside. $inall& sec"rit&
%eas"res %"st be in )lace to )revent "na"thoried "sers fro% atte%)ting to log into the
online banking section of the +eb site.
/aw cannot )ossibl& be eA)ected to kee) )ace with changes in technolog&. he recent
debacle of virt"al vo&e"ris% has bro"ght o"t a%ongst other things the inade0"ac& and
v"lnerabilit& of the laws governing "se of internet. $iAing liabilit& recording and
re)rod"cing evidence ascertaining "risdiction are )roble%s which show little sign of easing. (oncerns over sec"rit& and %is"se )ertaining to e-banking activit& have been
%o"nting as %ore banks in ndia fora& into electronic banking. E-banking activities
involve not "st banks and their c"sto%er b"t n"%ero"s third )arties too. nfor%ation
held b& banks abo"t their c"sto%ersC their transactions etc changes hands several ti%es.
t is i%)ossible for banks to retaining infor%ation solel& within their own co%)"ter
networks let alone a single "risdiction is i%)ossible. isks )ertaining leakage
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ta%)ering or blocking of data are s"fficientl& high to warrant ade0"ate legal and
technical )rotection. ndia has no law on data )rotection leave alone a law governing an
area as s)ecific as )rotection of data in electronic banking. nfor%ation sec"rit& in e-
banking )resents two %ain areas of risk: )reventing "na"thoried transactions and
%aintaining integrit& of c"sto%ers transactions. Data )rotection falls in the latter
categor&.
1./ REGU;ATOR= AND ;EGA; 4RAME7ORK:
+hile E-banking has i%)roved efficienc& and convenience it has also )osed several
challenges to the reg"lators and s")ervisors. everal initiatives taken b& the govern%ent
of ndia as well as the eserve Bank of ndia have facilitated the develo)%ent of
E-banking in ndia. he govern%ent of ndia enacted the ,ct 2777 which )rovides
legal recognition to electronic transactions and other %eans of electronic co%%erce. he
B has been )re)aring to ")grade itself as a reg"lator and s")ervisor of the
technologicall& do%inated financial s&ste%. t iss"ed g"idelines on risks and control in
co%)"ter and teleco%%"nication s&ste% to all banks advising the% to eval"ate the risks
inherent in the s&ste%s and )"t in )lace ade0"ate control %echanis%s to address these
risks. he eAisting reg"lator& fra%ework over banks has also been eAtended to E-
banking. t covers vario"s iss"es that fall within the fra%ework of technolog& sec"rit&
standards and legal and reg"lator& iss"es.
Data )rotection laws )ri%aril& ai% to safeg"ard the interest of the individ"al whose data
is handled and )rocessed b& others. nterestsC are "s"all& eA)ressed in ter%s of )rivac&
a"tono%& andor integrit&. Data )rotection laws are fra%ework lawsC )roviding rather
diff"sed general r"les for s"ch )rocessing and %aking allowances for develo)ing detailednor%s as and when the need arises. "ch legislation t&)icall& reg"lates all or %ost stages
of the data )rotection c&cle incl"ding registration storage retrieval and disse%ination of
)ersonal data.
he ndian nfor%ation echnolog& ,ct 2777 basicall& a fra%ework law %akes
hacking a )"nishable offence "nder ection !!. Breach of infor%ation sec"rit& is
i%)licitl& recognied as a )enal offence in the for% hacking. he a))ro)riate
govern%entC is e%)owered to declare an& co%)"terC co%)"ter s&ste%C
or co%)"ter networkC as a )rotected s&ste%. , ten &ear )rison ter% and a heft& fine
await an& )erson who sec"res access to the sec"red co%)"ter s&ste%C in contravention
of the )rovisions of the law.
8. ADVANTAGE O4 E-BANKING
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1. t re%oves the traditional geogra)hical barriers as it co"ld reach o"t to c"sto%ers of
different co"ntries legal "risdiction. his has raised the 0"estion of "risdiction of law
s")ervisor& s&ste% to which s"ch transactions sho"ld be s"bected t gives worldwide
connectivit&.
2. t has added a new di%ension to different kinds of risks traditionall& associated with
banking heightening so%e of the% and throwing new risk control challenges
3. /ower o)erating costs
4. , new for% of co%)etition has e%erged both fro% the eAisting )la&ers and new
)la&ers of the %arket who are not strictl& banks so there is %)roved or s"stained
co%)etitive )osition.
5. ncreased c"sto%er de%and for services
!. ?ew reven"e o))ort"nities
#. ,vailabilit& of in0"ir& and transaction services aro"nd the clockM
9. Eas& access to transaction data both recent and historicalM and Direct c"sto%er control
of international %ove%ent of f"nds witho"t inter%ediation of financial instit"tions inc"sto%erCs "risdiction.
$. CA;;ENGES AND ROAD AEAD
C%a&&enges:
nfor%ation technolog& anal&st fir% the eta 8ro") recentl& re)orted that financial
instit"tions who donGt offer ho%e banking b& the &ear 2777 will beco%e %arginalied.
B& the &ear of 2772 a large so)histicated and highl& co%)etitive nternet Banking
arket will develo) which will be driven b&
H De%and side )ress"re d"e to increasing access to low cost electronicservices.
H E%ergence of o)en standards for banking f"nctionalit&.
H 8rowing c"sto%er awareness and need of trans)arenc&.
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H 8lobal )la&ers in the fra&
H (lose integration of bank services with web based E-co%%erce or even
disinter%ediation of services thro"gh direct electronic )a&%ents .
H ore convenient international transactions d"e to the fact that the nternet
along with general dereg"lation trends eli%inates geogra)hic bo"ndaries.
H ove fro% one sto) sho))ing to GBanking *ortfolioG i.e. "nb"ndled
)rod"ct )"rchases.
(ertainl& so%e eAisting brick and %ortar banks will go o"t of b"siness. B"t thatGs beca"se
the& fail to res)ond to the challenge of the nternet. he nternet and itGs "nderl&ing
technologies will change and transfor% not "st banking b"t all as)ects of finance and
co%%erce. t re)resents %"ch %ore than a new distrib"tion o))ort"nit&. t will enable
ni%ble )la&ers to leverage their brick and %ortar )resence to i%)rove c"sto%er
satisfaction and gain share. t will force lethargic )la&ers who are str"ck with legac& cost
basis o"t of b"siness-since the& are "nable to bring to )la& in the new conteAt.
MAIN CONCERNS IN INTERNET BANKING
n a s"rve& cond"cted b& the Online Banking ,ssociation %e%ber instit"tions rated
sec"rit& as the %ost i%)ortant iss"e of online banking. here is a d"al re0"ire%ent to
)rotect c"sto%ersG )rivac& and )rotect against fra"d. Online Banking via the +orld +ide
+eb )rovides an overview of nternet co%%erce and how one co%)an& handles sec"re
banking for its financial instit"tion clients and their c"sto%ers. o%e basic infor%ation
on the trans%ission of confidential data is )resented in ec"rit& and Encr&)tion on the
+eb. *( againe Online also offers a )ri%er: 'ow Encr&)tion +orks. , %"lti-la&ered
sec"rit& architect"re co%)rising firewalls filtering ro"ters encr&)tion and digital
certification ens"res that &o"r acco"nt infor%ation is )rotected fro% "na"thoried access:
H $irewalls and filtering ro"ters ens"re that onl& the legiti%ate nternet "sers are allowed
to access the s&ste%.
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H Encr&)tion techni0"es "sed b& the bank wo"ld ens"re that )rivac& of data flowing between the browser and the
nfinit& s&ste% is )rotected.
H Digital certification )roced"res )rovide the ass"rance that the data &o" receive is fro%
the nfinit& s&ste%.
he %ain disadvantage of e-banking is the sec"rit& )roble%s that s"rro"nd it. tGs a fact
that %aking transactions online )oses a %"ch bigger risk co%)ared to %aking
transactions in a )h&sical branch. his is d"e to the hacking )roble%s and identit& theft.
,ddition to these risks technical diffic"lties co"ld also arise. o%eti%es the bankGs
website goes down and if this ha))ens it will be a hassle for the c"sto%er beca"se heshe
has to go to a branch or %ake )hone calls- which is "s"all& b"s& d"e to other c"sto%ers
also %aking a call. ,nother case that has ha))ened was an "n)redicted rise in c"sto%er
that the servers of the bank were not able to co)e with. , c"sto%er %a& also r"n into a
bad service. o%eti%es &o" %ight wait a while for &o"r checks to clear and &o" certainl&
canGt do an&thing abo"t it if it is online.
"r)risingl& technical iss"es do not a))ear to be the %aor constraint in the s"ccessf"l
ado)tion of electronic banking initiatives. Develo)ing and )ro%oting a val"e )ro)osition
to the c"sto%er that is high eno"gh to %atch the fleAibilit& and accessibilit& of cash. t
beco%es vital to design )rod"cts that offer a balance between co%)etitive )ricing
f"nctionalit& and s"fficient access )oints for basic transactions like de)osits andwithdrawals of cash.
(). CONC;USION AND RECOMMENDATIONS
+eb based banking service or E-Banking the latest generation of electronic
banking transactions has o)ened ") new window of o))ort"nit& to the eAisting
banks and financial instit"tions.. ince its evol"tion in 67 th decade it is having
"n)recedented growth. he E-Banking sector is highl& )rohibitive for the new
entrants altho"gh the ince)tion cost is lower with high growth rate. he brand
)reference of the c"sto%er eAisting network )h&sical eAistence sec"rit& andsafet& s"))lier bargaining )ower s"bstit"te )rod"ct of non-banking sectors have
%ade the wa& thorn&. 'owever new co%er with innovative idea and strateg&
definitel& can %ake )osition in this sector. he anal&sis of the evol"tion and
)resent stat"s of E-Banking %ake "s so%e roo% to %ake co%%and%ents for the
govern%ent new entrants and eAisting e-banks for effective "tiliation of the
o))ort"nit& to accelerate the econo%ic growth.
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nternet )enetration is a %aor factor for the growth of E-Banking. here is a
strong )ositive correlation between nternet "sage and E-Banking "sage.
'owever nternet )enetration alone does not g"arantee online banking
)enetration. n this sit"ation co%)anies can give incentives s"bsidiing the
s"rfing cost free training %"lti)le access facilit&
%otivation )rogra%s to the "ser and the )o)"lation as a whole.
Ttandard or (o%%on and at"re technolog& is alwa&s a )roble% in this 'i-ech
age. etting ") electronic banking re0"ires s"bstantial invest%ents and it is ver&
co%)licated to %ove fro% old technologies to new ones. h"s banks can
coo)erate closel& in the field of develo)ing standards to offer services to third
)arties.
TE-Banks %"st take aggressive %arketing effort. t has been seen that the
%arketing efforts %ade to )ro%ote Estonian nternet banking have been
contin"o"s and aggressive in different %edia channels and in bank branches.
nnovative )rod"cts which have been )ro%oted eAtensivel& have a higher chance
of s"ccess in the %arket than si%ilar )rod"cts witho"t the co%%"nications
s"))ort.
T,ll of the efforts to establish an internet onl&C %odel E-Banking of b"siness has
not been s"cceed &et. h"s there %"st be a )h&sical eAistence of the bank and E-
Banking co"ld be an eAtent to that o)eration. t will give the c"sto%ers an
i%)ression of sec"rit& and safet&. Besides anal&sis showed that the senior citiens
all over the world like to acco"nt with brick and %ortar banks. ,voiding the% the
e-banks wo"ld loose a large )ortion of their c"sto%ers.
TE-Banks %"st tr& to eA)and their network as soon as )ossible. ,s %ore and %ore
third )art& will involve in the network the& co"ld attack %ore c"sto%ers.
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8overn%entsC %ain role is enhancing the enabling environ%ent as it is known
that the direct intervention into financial %arkets %a& have )oor res"lts. n
general a laisse faire a))roach to the reg"lation and s")ervision of the econo%ic
)olic& will foster )ositive attit"des nationwide.
he e-banks %"st tr& to achieve critical %ass. ,chieving critical %ass is ke&
s"ccess factor in electronic banking develo)%ent. his can be achieved when
there is s"bstantial nternet )enetration and banks are able to )rovide services
which have ver& broad de%and. n this case the satisfied "sers will serve as
endorsers and %arketers of the service. he )ower of )erson-to-)erson
co%%"nication and word of %o"th can never be "nderesti%ated.
Re#e'en*es:
1. isk anage%ent in Electronic Banking: (once)ts and Best *ractices b& Na&ara%
=ondabagil
2.http://www.ffiec.gov/ffiecinfobase/booklets/e_banking/ebanking_00_intro_def.ht
ml
3.http://www.fdic.gov
4.http://www.banknetindia.com/banking/ibkgintro.htm
5.www.ncua.gov
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