Compliance Center: FFIEC Issues IT Examination Appendix for Mobile Financial Services

The Federal Financial Institutions Examination Council (FFIEC) issued a revised Retail Payment Systems booklet, which is part of the FFIEC Information Examination Handbook (IT Handbook).  The update consists of the addition of a new appendix, Appendix E: Mobile Financial Services.

The Retail Payment Systems booklet contains guidance to assist examiners in evaluating financial institution and third-party provider management of the risks associated with retail payment systems.  Appendix E contains guidance pertaining to mobile financial services risk that supplements existing booklet guidance on other retail payment topics, such as electronic payments related to credit cards and debit cards, remote deposit capture and changes in retail payment systems technology.

Mobile financial services are the products and services that a financial institution provides to its customers through mobile devices. Appendix E focuses on the risks associated with mobile financial services and emphasizes an enterprise-wide risk management approach to effectively manage and mitigate those risks. It also contains a separate set of work-program objectives to assist the examiner in determining the state of risk and controls at an institution or third party providing mobile financial services. Financial institution management should also find this guidance helpful.

This appendix addresses the following:

  • Mobile financial services technologies;
  • Risk identification;
  • Risk measurement;
  • Risk mitigation;
  • Monitoring and reporting.

The IT Handbook is available at

Compliance Question of the Week

What is considered positive owner contact that would prevent an account from going dormant?

Savings and checking accounts are abandoned if there is no positive owner contact for three years. Positive owner contact is any documented contact initiated by the owner, including:

  • Deposits;
  • Withdrawals;
  • Correspondence;
  • Phone calls;
  • Address changes;
  • Activity on a related account.

Positive owner contact does not include:

  • Unreturned mail;
  • Automatic interest transfers (except the first one);
  • Automatic payments;
  • Internally-initiated address changes (such as adding plus four digits to the zip code);
  • Service charges.


ORS 93.308
RCW 63.29.060
IDS 14-506

Legal Briefs

National Credit Union Administration (NCUA)

NCUA Chairman Metsger announced that the NCUA will begin a thoughtful and thorough review of the examination process. Anthem spoke to new Board Chair Rick Metsger about the change last week.

Consumer Financial Protection Bureau (CFPB)

The CFPB released new TRID tools that provide disclosure citations for the Loan Estimate and Closing Disclosure.

The CFPB issued a Fair Lending Report to Congress. This is the CFPB’s fourth report that describes the CFPB’s fair lending activities in prioritization, supervision, enforcement, rulemaking, research, interagency coordination, and outreach.

Federal Reserve Board (FRB)

The FRB announced that it has temporarily suspended its acceptance of uncurrent coin deposits.

The FRB released the minutes of its May Federal Advisory Council meeting. The meeting minutes recap the current market conditions, shadow banking and market-based finance, bond market liquidity, and monetary policy.

The FRB has released the May 2016 issue of FedFlash.  

Department of Justice (DOJ)

The DOJ has released a Supplemental Advance Notice of Proposed Rulemaking regarding the revising of its Title II website requirements. The notice is seeking public comment on the establishment of specific technical requirements to make state and local government services, programs, and activities more accessible to the public via the web.

Federal Trade Commission (FTC)

The FTC released guidance for employment background screening companies and what they should know regarding the FCRA.

Department of the Treasury (Treasury)

The Treasury announced the release of its white paper on online marketplace lending. The whitepaper contains research and recommendations for the industry to encourage safe growth and access to credit.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of May 13, 2016. The last update prior to this was May 11, 2016.

Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News, NCUA.