We were not OTS. We allowed the first phase of internet banking to be allowed w/o a signature. When transfer capabilities came about and real money was at risk, instead of just confidential information, pen & ink signatures were required and security practices enhanced.
That said, I just spent a few minutes looking but didn't see it. I thought there was a post recently where the OTS did have additional restrictions apart from other agencies, but I think it was notice to them that you'd have a web site. I could be wrong and am not a guru on OTS rules. Still, some authorization you can trace back is always wise.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell