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Question & Answer
Question: Should a virtual branch have the required lobby posters, such as the CRA notice and the fair lending notice?
Answer: Who knows? But we think it is a good idea. Until we have clear answers to how to comply with regulations in the context of electronic or virtual banking, it is wise to comply with any rules that would apply to an in-person transaction conducted in a brick-and-mortar building.
Fundamentally, compliance rules deal with providing information to the consumer. So far, the fact that a consumer is an Internet customer is not justification for withholding that information.
Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 3, 3/00
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