It is an internet jungle out there. I attended an internet compliance class recently and felt fairly confident about my answers to the instructor's "test" questions. After all, I've been a compliance officer at our community bank for 12 years. I think I violated every letter of the alphabet--some twice! A question from a customer as simple as "what are you paying on your CDs today" can get you into hot water.
As we move forward, we have developed a policy (of course), we are working on standard script answers to common customer questions, we have brought our affiliate banks onto an intranet to keep our transmitted data internal (it does not go out into the general internet world) and we have set restrictions on non-business type web sites. If you try to access a shopping site, for example, the system stops you and tells you that the site is restricted.
We are currently working on procedures to accept deposit account applications online. I feel my compliance head hurting.
I welcome any suggestions for navigating online account applications.