【正文】 itutions. Since transactional websites typically enable the electronic exchange of confidential customer information and the transfer of funds, services provided through these websites expose a financial institution to higher risk than basic informational websites. Wholesale ebanking systems typically expose financial institutions to the highest risk per transaction, since mercial transactions usually involve larger dollar amounts. In addition to the risk issues associated with informational websites, examiners reviewing transactional ebanking services should consider the following issues: —— Security controls for safeguarding customer information。 —— Liability for unauthorized transactions。 —— Possible violations of laws or regulations pertaining to consumer privacy, antimoney laundering, antiterrorism, or the content, timing, or delivery of required consumer disclosures. 2. Transaction risk 3 Transaction risk arises from fraud, processing errors, system disruptions, or other unanticipated events resulting in the institution’s inability to deliver products or services. This risk exists in each product and service offered. The level of transaction risk is affected by the structure of the institution’s processing environment, including the types of services offered and the plexity of the processes and supporting technology. In most instances, ebanking activities will increase the plexity of the institution’s activities and the quantity of its transaction/operations risk, especially if the institution is offering innovative services that have not been standardized. Since customers expect ebanking services to be available 24 hours a day, 7 days a week, financial institutions should ensure their ebanking infrastructures contain sufficient capacity and redundancy to ensure reliable service availability. Even institutions that do not consider ebanking a critical financial service due to the availability of alternate processing channels, should carefully consider customer expectations and the potential impact of service disruptions on customer satisfaction and loyalty. The key to controlling transaction risk lies in adapting effective polices, procedures, and controls to meet the new risk exposures introduced by ebanking. Basic internal controls including segregation of duties, dual controls, and reconcilements remain important. Information security controls, in particular, bee more significant requiring additional processes, tools, expertise, and testing. Institutions should determine the appropriate level of security controls based on their assessment of the sensitivity of the information to the customer and to the institution and on the institution’s established risk tolerance level. Generally, a financial institution’s credit risk is not increased by the mere fact that a loan is originated through an ebanking channel. However, management should consider additional precautions when originating and approving loans electronically, including assuring management information systems effectively track the performance of portfolios originated through ebanking channels. Funding and investmentrelated risks could increa