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#12228 - 12/08/00 01:47 AM COPPA
Richard Insley Offline
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Does anyone have, or have you seen a bank website that is covered by and compliant with COPPA?
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#12229 - 12/08/00 02:04 PM Re: COPPA
Andy_Z Offline
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I know of none that are compliant with it, and none that try to collect information from kids.

I fear though, that many of us are subject to it without realizing it.

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Andy Zavoina
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#12230 - 12/08/00 04:47 PM Re: COPPA
Mary Beth Guard Offline
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Love a challenge! I haven't found any that are l) subject to COPPA and 2) in compliance with COPPA, but I found a wonderful site that I believe should be complying, but does not appear to be. I believe it should be complying because it has an ask an expert form that gathers personal information, etc. What do you think?
http://www.kidsbank.com/

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#12231 - 12/08/00 07:08 PM Re: COPPA
Andy_Z Offline
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Since COPPA includes "individually identifiable information about a child that is collected online, such as full name, home address, email address, telephone number or any other information that would allow someone to identify or contact the child", I would say that "Ask Mr. Money" qualifies. The child's name is a required field.

Related, whitehouse.gov asks for the kids info as well and has been cited as noncompliant.

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Andy Zavoina
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AndyZ CRCM
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#12232 - 12/26/00 09:04 PM Re: COPPA
Anonymous
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I think the Disney website is covered by COPPA and is intended to comply. This is per their privacy guru at a Wash DC seminar last month concerning the topic. Her name was Alden LNU.

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#12233 - 12/28/00 12:50 AM Re: COPPA
Richard Insley Offline
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So let's see.......

In three weeks we've indicted the White House, failed to locate a single bank that is covered & compliant and determined that Mickey Mouse MIGHT be compliant!

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#12234 - 01/09/01 12:12 AM Re: COPPA
Anonymous
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Since COPPA prohibits collecting information from children without first obtaining parental consent, I think that puts the onus on the bank to ensure that someone submitting an online application (to open an account, apply for a loan, sign up for internet banking etc.) affirms that he/she is at least 18 years old.

I noticed that Wingspan has this on its online application (https://marketing.wingspanbank.com/IBServlet), but a lot of banks do not.


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#12235 - 01/09/01 02:20 PM Re: COPPA
Andy_Z Offline
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You are absolutely correct, Susan.

Initially I thought this was just for sites that targeted children, but that is not the case.

I have added an "Must be 18 or older" warning to all my online applications.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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AndyZ CRCM
My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#12236 - 01/19/01 03:34 AM Re: COPPA
Anonymous
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Upon further review, I noticed that the info gathering page must be targeted toward children or responses from children are expected. I should have read more before submitting my previous post. However, I still think having the applicant affirm he/she is at least 18 is a good idea.

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#12237 - 01/19/01 04:37 AM Re: COPPA
Andy_Z Offline
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I really tend to agree with your original post. On the FTC's site that addresses "How to Comply With COPPA", they state COPPA applies to a site "that collects personal information from children or if you operate a general audience Web site and have actual knowledge that you are collecting personal information from children".

If your online application includes their age, you have actual knowledge. I have heard an inference to this effect from a senior regulatory official. Whether all agencies adopt this or enforce it remains to be seen. But it is an easy risk to mitigate, "Must be 18 or older to apply (online)".

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

[This message has been edited by Andy Z (edited 01-18-2001).]

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AndyZ CRCM
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#12238 - 01/19/01 11:56 AM Re: COPPA
Richard Insley Offline
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I agree with Andy's take on this--and besides, how many banks want to make loans to or contract with 12 year olds?
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#12239 - 12/04/02 04:44 PM Re: COPPA
Happy Offline
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I realize this is an old thread but I wanted to know if any of you out there have been examined by the FDIC or OCC regarding COPPA. If so, my questions is in regard to links on our website. Are we responsible if a site that we are linked to is in violation of COPPA? If we have the warning when they leave our site are we ok?

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#12240 - 12/04/02 04:56 PM Re: COPPA
Andy_Z Offline
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You should look at the OCC issuance on Weblinking and COPPA compliance examining procedures. While I don't believe you are responsible for someone else's site that you link to, you should have a notification that advises the user they are leaving your site and the terms and conditions may vary from yours on any other site the user goes to.

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AndyZ CRCM
My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#12241 - 12/04/02 08:01 PM Re: COPPA
Happy Offline
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Andy, do you have a link for that? I tried searching the OCC site and did not find it. Thanks

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#12242 - 12/04/02 08:04 PM Re: COPPA
complyguy Offline
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PA
I have the source as OCC Bulletin 2001-31.

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#12243 - 12/04/02 08:44 PM Re: COPPA
Andy_Z Offline
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#12244 - 12/04/02 09:39 PM Re: COPPA
Happy Offline
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Happy
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Thanks. You guys are so efficient.

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#12245 - 12/05/02 12:02 PM Re: COPPA
Richard Insley Offline
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Before breathing a sigh of relief, you need to examine the nature of the linked relationship. If you're linked to fun & games sites, no problem. If you're linked to a vendor that is paid to host content on the bank's behalf, including pages with forms that gather personal info from kids, you should treat this content as an extension of your site.
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#12246 - 12/05/02 01:01 PM Re: COPPA
Ann Offline
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Just tagging on here...I guess I have no life, but out of curiosity, I checked the FDIC Learning Bank for the information it collects on children; nothing too personal other than what grade they are in. But for those of you who remember the discussion we had several months ago about the first FDIC check given to Ms. Lydia Lobsiger for deposits in an insured closed bank - the picture of that check has been removed. Guess when they realized bankers were looking at that check and asking questions, they were embarrased at their error.

My opinions are my own and not those of my employer.

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#12247 - 12/05/02 03:28 PM Re: COPPA
Andy_Z Offline
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I haven't re-visited the site, but soon after COPPA was in force, the whitehouse.gov's kids pages were in violation. I'd assume that is fixed since George W has a different Web team than Bill did. But we know about assumptions.
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R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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