We are an OCC regulated bank. Our internet provider is telling us that we are not required to disclose a terms and conditions disclosure on our website. (This disclosure lists any restrictions or limitations related to our online banking products.) Is our internet provider correct? Would we be out of compliance if we didn't provide this information on our website? Does anyone know where I can find specific regulatory guidance addressing this issue? Thanks.

Your terms and conditions are part of your service agreement (contract) which must be executed by each customer who applies to receive the services. Contracts should be drafted by bank counsel and presented to customers at the time and in the manner counsel advises. If you are contracting electronically, prior customer consent to electrons vs. paper is needed. The consent process is governed by either ESIGN or your state's UETA. If you are opening new deposit or credit accounts in the process of establishing the e-service package, follow the familiar new account disclosure rules (plus e-delivery if applicable) of the Truth regulations and Reg. E (if you are establishing a new access device that was not previously disclosed.)