【正文】 e 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 increase with an institution’s ebanking initiatives depending on the volatility and pricing of the acquired deposits. The Inter provides institutions with the ability to market their products and services globally. Interbased advertising programs can effectively match yieldfocused investors with potentially highyielding deposits. But Interoriginated deposits have the potential to attract customers who focus exclusively on rates and may provide a funding source with risk characteristics 4 similar to brokered deposits. An institution can control this potential volatility and expanded geographic reach through its deposit contract and account opening practices, which might involve faceto face meetings or the exchange of paper correspondence. Compliance and legal issues arise out of the rapid growth in usage of ebanking and the differences between electronic and paperbased processes. Ebanking is a new delivery channel where the laws and rules governing the electronic delivery of certain financial institution products or services may be ambiguous or still evolving. Laws governing consumer transactions require specific types of disclosures, notices, or record keeping requirements. These requirements also apply to ebanking, and banking agencies continue to update consumer laws and regulations to reflect the impact of ebanking and online customer relationships. Institutions that offer ebanking services, both informational and transactional, assume a higher level of pliance risk because of the changing nature of the technology, the speed at which errors can be replicated, and the frequency of regulatory changes to address ebanking issues. The potential for violations is further heightened by the need to ensure consistency between paper and electronic advertisements, disclosures, and notices. 3. Risk management Ebanking has unique characteristics that may increase an institution’s overall risk profile and the level of risks associated with traditional financial services, particularly strategic, operational, legal, and reputation risks. These unique ebanking characteristics incl