Quick question, when we put a link on our website to another site are we required to provide a disclosure (pop-up) that indicates to the customer that they are now leaving our bank's website and going to another? If so, where can I find out where it says this is needed. Thanks in advance!!
Posted By: MN Comply Guy
Re: Links from our site - 04/02/08 09:23 PM
You should check out the interagency guidance "Weblinking: Identifying Risks and Risk Management Techniques." You can find it as an attachment to FIL-30-2003.
OCC Bulletin 2003-15 discusses this. Even if you're not OCC regulated, this information was also issued by the FDIC, NCUA and OTS (not sure why the FRB wasn't part of it).
http://www.occ.treas.gov/ftp/bulletin/2003-15a.pdfYou may want to scroll down to page 8 and read the section on "Disclaimers" first.
Posted By: Andy_Z
Re: Links from our site - 04/03/08 04:11 AM
It isn't a requirement, but the speed bump is a best practice. It need not be a pop-up though as many people block those. Some sites group/segregate and even color code internal links from external ones. Those externals are denoted as being away from your site and your control.