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#1687759 - 04/11/12 01:33 PM Weblink Disclosure
Auditor412 Offline
Member
Joined: Jun 2011
Posts: 51
Midwest, United States
After reviewing our bank's websites, I'm a little confused regarding the disclaimer notifying users that they are leaving the site. It was my belief that if the link took the user to another site that was not the bank's site the disclaimer should be present. Is there a difference if the selection of the link opens a new window or continues to the site? Any assistance is greatly appreciated as I'm forseeing pushback from management based on my findings! Thank you!!

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eBanking / Technology
#1687764 - 04/11/12 01:40 PM Re: Weblink Disclosure Auditor412
A_G Offline
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Joined: Jul 2004
Posts: 18,989
http://www.fdic.gov/news/news/press/2003/pr3403a.html

Implementing Weblinking Relationships section...

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#1687776 - 04/11/12 02:13 PM Re: Weblink Disclosure Auditor412
Auditor412 Offline
Member
Joined: Jun 2011
Posts: 51
Midwest, United States
Thank you! I'd provided this press release as part of my reserach. So, just to verify....the way the website opens does not constitute whether or not the disclaimer is needed. To me this seems simple but sometimes convincing others they need to make changes is the hardest part!

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#1687780 - 04/11/12 02:21 PM Re: Weblink Disclosure Auditor412
Richard Insley Offline
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Richard Insley
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Posts: 10,180
Toano, VA
To what kind of external sites are you linking?
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#1687782 - 04/11/12 02:23 PM Re: Weblink Disclosure Auditor412
Auditor412 Offline
Member
Joined: Jun 2011
Posts: 51
Midwest, United States
IRS, Yahoo Finance, American Portfolios, Equifax, Transunion, etc. Most of them relate to mortgages and investments.

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#1687808 - 04/11/12 03:08 PM Re: Weblink Disclosure Auditor412
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Since the guidance applies to "links to third parties that offer products, services, or information directly to financial institution customers," then links to the sites you listed should be covered. The guidance focuses on your reputational risk, not the mechanism used to reach the external sites.
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#1687818 - 04/11/12 03:24 PM Re: Weblink Disclosure Auditor412
Auditor412 Offline
Member
Joined: Jun 2011
Posts: 51
Midwest, United States
Thank you!

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#1688507 - 04/13/12 02:32 AM Re: Weblink Disclosure Auditor412
Paul Marshall Offline
Junior Member
Joined: Mar 2010
Posts: 33
I would like some clarity on this...do all sites that arent within the bankname.com domain have to have a speed bump?

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#1688516 - 04/13/12 07:50 AM Re: Weblink Disclosure Auditor412
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Hit the link Mr. A_G-DDD provided and review the Guidance. Generally, you'll find the answer to be "yes", but there's some flexibility. Also, notice that the Guidance is 9 years old. The WWW was a different "place" then, and the agencies' views have most likely evolved without additional guidance.
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