Our Marketing department (God Bless 'em!) is in the process of redesigning our Web Site. As part of the redesign, they have created a "static bar" that contains drop down boxes to navigate the site, and has the FDIC logo at the bottom. This bar is visible regardless of what page you go to on the site, and cannot be minimized or closed. Is this a problem if a customer goes into a page on our site that advertised products that are not FDIC insured? For example, if someone goes to our investment services page, the "not-not-may" disclsoures are on that page, but the FDIC logo is on the static bar and is still visible. My marketing people say, "Tell me where it says we can't do this!", and truthfully, I can't find anything that says that. There are clear and conspicuous requirements, and requirements not to confuse the customer about what is and is not FDIC insured, but they feel this format meets those requirements. Does it? I have looked at several other bank Web sites, and none that I have found do this. Any ideas?

I believe that the disclosures as you mention them can be done, if made clear that one frame is separate from another, but you greatly increase the chance of criticism because the consumer may be confused. Other banks are likely not doing this type of layout because the risk is to great.

Regulatory criticism is one thing, but in today's declining economy, do you want the risk of your customers who have now lost serious money in the market for the first time coming to you and saying they saw the insurance disclosure, how could they lose money? It is subjective and it is risk management.

You do not have to have a licence to use the Web, and many people exemplify this. They'll get confused over anything. And especially if it costs them money.

I had a message last night from a user who complained that there was no way to go from our Web site to access her accounts. She thought another sites "My Account" link was the only way to go and we should have one. I pointed out that the blue and white "Internet Banking" button on the left of each of our pages would be a good start.

The risks here can vary, and can be substantial. Personally, I'd push to separate them. It is doable.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.