There may be some variances for Web only banks.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
The Federal Reserve has a simulated website for banks to use as training and I don't see anything pertaining to CRA on it.
I will say this - the CRA regulations are up for review by the agencies in 2002. I would expect to see some issues addressed then about what needs to be posted on a bank's website. I would not be surprised to see a recommendation that at least the CRA notice become a requirement, if not the public file itself.
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Jim Bedsole, CRCM, CBA, CFSA
Opinions expressed are my own, and do not necessarily reflect those of my employer.
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Jim Bedsole, CRCM, CBA, CFSA
Opinions expressed are my own, and do not necessarily reflect those of my employer.
One could argue that if you are opening accounts (loans or deposits) on the Web you are establishing a relationship at that time, and depending on how you do this a Privacy notice may be required then. But if your site is advertising this shouldn't be "required" as no relationship is being formed as a result of that.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
Also, the CRA review opens the door to cyber requirements, since the assessment area in cyberspace is going to be one of the issues under discussion.
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Jim Bedsole, CRCM, CBA, CFSA
Opinions expressed are my own, and do not necessarily reflect those of my employer.
I believe a case can be made that while privacy notices are not required on the Web, they may be depending on what you do on the Web.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
1. It makes your Privacy Policy readily available to anyone who would like to read it.
2. Most Net-Consumers are getting savy and proactively LOOK for the Privacy Notice on a web site where they might want to conduct business. Not having the Notice could give people pause to even consider your bank.
Just IMHO.
[This message has been edited by Bonnie M (edited 06-12-2001).]
I also like being able to add to the Net version so that non-techies are not confused with discussions of cookies and some of those things generally added specifically for the Web.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
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Jim Bedsole, CRCM, CBA, CFSA
Opinions expressed are my own, and do not necessarily reflect those of my employer.