On August 24, 1998 the Office of the Comptroller of the Currency ("OCC") advised banks on ways to identify and control risks arising out of banks' use of personal computer ("PC") banking. The Bulletin also laid out the OCC's expectations of bank management and boards of directors when the bank operates a PC banking system, and suggested that all banks that provide or are planning to provide PC banking should follow the guidelines.
Among the advice contained in the Bulletin, the OCC recommends that banks adopt thoroughly-tested security controls, including data access controls, encryption, and virus protection. Further, banks should monitor changes in consumer and banking laws, and should take adequate measures to comply with them. In addition, the OCC recommended that banks consult with legal counsel to ensure that they have enforceable contracts with their PC banking customers, particularly if electronic contracting is being used to sign customers up for the service.