Remember that your credit union’s responsibility for mitigating risk doesn’t stop when you flip the switch to turn on PIB.  Your policies and procedures related to offering and supporting home banking services for members are just as important. 

Make sure you have also considered:

• Your password controls and education program.
• How you manage resetting passwords for members.
• Your policies and procedures for how home banking is implemented for new memberships.
• Policies for expiring passwords when members don’t use home banking regularly.
• How home banking access is covered in your dormancy policies and procedures.
• Your approach for how members move money on the Internet.
• Your approach to how members manage their identity on the Internet.

Remember, it’s not just the tools you use (It's Me 247); it’s the strategies that set the tone for where you are going with Internet services.  It’s the behind the scenes, people things in your office that create the overall Internet risk you have.  How easy is it for someone to call a credit union employee and have a password reset without identifying themselves?  This isn’t technical; this is social.