“Clicks and bricks”:
The banking industry realizes that a vital and profitable segment of its clientele demands a significant online presence that complements the traditional “bricks and mortar” presence. A virtual minefield of traditional and new issues and risks arises as banks adopt 24/7 transactional websites in their pursuit of a “clicks and bricks” strategy. Banks face operational, security, legal, and reputation risk with their foray into online banking. An innovative and proactive approach to risk management is essential as banks move into this new territory. Recent regulatory and legislative developments suggest that as electronic banking evolves, the earlier regulatory stance of “self-regulation” appears to be changing to one of increased scrutiny.