For the record and the benefit of others, OTS requires advanced notice in 12 CFR 555.300:
"You must file a written notice [with OTS] as described in Sec. 555.310 before you establish a transactional web site. A transactional web site is an Internet site that enables users to conduct financial transactions such as accessing an account, obtaining an account balance, transferring funds, processing bill payments, opening an account, applying for or obtaining a loan, or purchasing other authorized products or services."
Opinions are mine not my employer's, and should not be taken as legal advice.