Could web site links put your institution at risk? The regulators think so, and the OCC, FDIC, NCUA and OTS just issued a joint press release highlighting the issue.
So, before you get hit with the implementation and ramifications of the final PATRIOT Act CIP rules, it's a good time to review your web compliance. With all the agencies coming together on this issue, you can bet that it will remain a focus. You'd better stay one step ahead and follow the guidance. And we'll help.
In A Nutshell
Any time your web site links to a third-party web site, you put your institution at some level of risk. Customer confusion about the relationship could result in reputational risk to your business. What can lead to this confusion? The agencies spell out three primary factors.
nature of products and services;
trade name of the third party; and,
web site appearance.
What Do You Need To Do?
Managing the risk becomes your most important goal. There's a lot of helpful advice found in this document. In addition to due diligence, planning, and written agreements, the agencies give advice on disclaimers and disclosures, managing service providers, and monitoring.
Where does this leave you? Should you restrict the ability of your customers to link from your site? Maybe. But by following the agencies advice along with some great content we've included below, you should be able to manage the situation to provide your customers with a satisfying web experience while protecting your institution.
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