If #1 Bank has subsidiaries which are other financial institutions (i.e., #2 bank and #3 mortgage company) and #1 Bank has links to #2 and #3 from their website, are disclosures required? The FDIC issued guidance regarding weblinking to third parties, but after reading SEVERAL times, I don't see that it clarifies this situation.

First, the link disclosures are not a written requirement.

Second, they are a best practice so the user knows that they are leaving your site, other privacy policies may apply and there may be different rules for data gathering, cookies, products and services, etc.

Because these affiliates may differ, I'd keep the link disclosures in place. If you have one webmaster and all three sites are in sync, rule wise, you may choose not to use them.

If it were me, I'd add them and move on. They aren't that big a deal to add.

Thank you. But one more thing. I'm using the Web checklist provided in Banker's Tools by Debra - I think it is, p. 11, Section 16 indicates that "viewers should be able to activate the link (Member FDIC) and with a click of their mouse read everything they want to know about insured deposits." Hmmm, is that just a suggestion or requirement? I've viewed many other bank's websites and don't see that they are doing this, and cannot locate in any other written form that this is required.

It is only a suggestion. I agree with that one and in some cases banks will link that to the Bank ID section so a user can verify the bank is authentic. In the phishing perspective, this is a good idea to separate you from possible hoaxes.

Similarly, I like to link the EHL logo to HUD or your EHL poster on your website.

Andy's right, the link is a suggestion. If you use the link, you will want to make sure that the link works; sometimes page.s get moved, and you will get the message "page not found" or something similar; a little frustrating for your web surfers.