Our bank is very close to making internet banking active for the general public. I was asked recently to enroll so that I could examine the site for potential Compliance issues.
Our internet banking product will, as is normally the case, be accessed from our bank website. I review the bank website quarterly for compliance and find no issues at present. However, I noticed that "Member FDIC" is nowhere on the internet banking site. I mentioned this to the Internet Banking (IB) team and stated that I had normally seen the FDIC membership reference somewhere next to or near the bank's name on each page on other internet banking sites I use. The IB team contacted our internet banking software vendor who stated that 1) they could not add this, 2) none of the other banks that they supply has asked for it nor have they ever had anyone question it, and 3) they were certain that the "Member FDIC" on the bank's website main page (which is where the sign-on for internet banking is) automatically takes care of this.
Trying to be proactive and protect my bank, I am concerned that the absence of the membership advertisement will come back and bite us.
I've looked high and low and can't seem to find any concrete reference showing the need for the membership advertisement on internet banking pages. (By-the-way, we have no NDIP or other references on the internet banking site which would hinder our use of the membership advertisment on any/all pages).
Common sense says that we should always use the membership advertisement unless contradicted. Any thoughts or helpful suggestions?
Thanks,