Archiving Web Site Changes
by Andy Zavoina and Richard Insley, BOL Gurus Guru BIOS
Question: I am trying to find out the format you recommend for us to save our Web site in before and after we make changes to it. Would you please advise the format?
Answer by Andy Zavoina: Speaking with regulators, having it is key. If you used animated GIFs or sounds, e-form is best and likely burned to CD/DVD is best. (Assuming it is a quality burn. There are DVD issues coming to light.) A simple site could be printed, but paper would not be my first choice.
Consider if you want to view the pages, or the site as a whole including your internal links. This will help you on the format.
Answer by Richard Insley: I'll add Adobe Acrobat to the list of possibilities, but the vast differences in the levels of sophistication among bank web sites rules out a "one size fits all" retention solution.
Generally, each reg require you to retain "evidence of compliance" with the substantive parts of that reg, not "copies of pages." If you're trying to meet the Reg DD retention requirement for a deposit interest rate board page, you can probably use anything from paper on up. On the other hand, if you're trying to document that the series of links throughout your site do not result in prescreening or steering (a Reg B problem), you need to retain the interlinked pages electronically so you can demonstrate the links/behavior to your next examiner.
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