We offer branded credit cards issued through a 3rd party. The issuer wants us to include a banner on our webpage that includes an "Apply Now" link. I know that we need to set up the speed bump, but is there anything else we need to do from a disclosure standpoint?

I wouldn't think so, "you're leaving our site, this site may have different policies..." I'm not sure what else could be said.

Thanks Andy. I finally got the finished weblink from the issuer. When I get to their page, there is nothing showing their name. No mouseprint that they are even running the site. They branded the whole page, so it looks like a bank controlled site. Shouldn't there at least be a disclosure somewhere on the site that they are the issuer/creditor?

I'm wondering the same thing. Dani - were you able to get any further guidance on this? In reading the 3rd party weblinking guidance, it would appear that even though the bank's name is all over the page, we'd still have to have the speedbump as this is a third party product.