Logos and pictures:
- Is FDIC logo on all pages with depository accounts? It should.
- Is FDIC logo on any page listing any brokerage type investment accounts? A no-no.
- Is Equal Housing Lender logo and legend on pages listing home credit products? It should.
- Is any picture or drawing of a human likeness used on any page? Look at entire site for possibility of discouraging specific >
- Are products listed actually available?
- Are advertised rates accurate? Are the APYs/APRs?
- Are the rates and APYs displayed equally? Are rates and APRs displayed equally?
- Is the term "Annual Percentage Yield" used at least once? Cannot use just "APY".
- Is the term "Interest rate" used and not just "Rate"?
- If an APY is quoted, is there a disclosure stating it is accurate as of a specific date?
- If an APY is quoted and the product uses a variable rate, is there a disclosure stating the rate may change after the account is open?
- If an APY is quoted, is there a disclosure stating fees may reduce earnings?
- If an APY is quoted and it is a CD, is there a disclosure stating the term and that a penalty may be applied for early withdrawal?
- Is the term "free" used with any product? If so, is the product truly free?
- If a minimum balance required to qualify for a specific rate, is it clearly disclosed?
- If an opening balance is required, is it clearly disclosed?
- Are there any stipulations on specific products on who can apply? Ex. Corporations cannot have NOW accounts. Are the stipulations disclosed?
- Are products that are FDIC insured and those that are not clearly discernible?
- Do brokerage type products have the three necessary disclosures? 1) are not insured by the FDIC, 2) are not deposits or guaranteed by your bank, 3) subject to risks including the loss of principal.
- If it is a loan product and a finance charge is mentioned by amount, is the term APR used?
- If it is a loan product and down payment is mentioned, is the amount or percentage required disclosed?
- If it is a loan product and payments, time period or amount are mentioned, is the total terms of repayment disclosed? You will need the number of payments, the amount and payment timing.
- If it is a loan product and a reduced rate is offered initially, is the limited term disclosed?
- If it is a loan product and the rate can increase after the account is opened, is this disclosed?
- Are disclosures presented in a "clear and conspicuous manner"?
- Are disclosures in line with regulations?
- If using the same group of disclosure for walk in customers, verify both web and paper copies match.
- Is there a disclosure on the use of the bank's website? May be listed as legal notice.
Calculators and Links:
- Does each calculator operate accurately?
- Do all links go where they should?
- Is there a disclaimer whenever leaving the bank's site for every external link?
- Is there a procedure in place to retain all data from the website on any given day? This includes all "blinking" text, as well.
- Is there a way or procedure in place for individuals to get a hard copy of the disclosures if they want?
- If disclosures change, is there a way for customers to have access to the prior disclosures for 90 days? Or a means to get a paper copy?
First published on BankersOnline.com 3/8/02
First published on 03/08/2002