Notice on the web page

We do not take applications for deposit accounts or loan accounts so would we still have to provide a notice on our web page?
My interpretation is no.

Thanks

You do not need to place the notice on your web site since you don't open accounts over the internet. Luckily, there is a lot of flexibility with the notice since it can be as simple as a lobby notice or a verbal notice.

I would say that if your website allows for customers to download applications or request one to be mailed to them, you should consider posting the CIP notice.

That is the route that we took...

The answer is that it is not required. Putting it there can provide the disclosure early, but it is difficult to ensure it was in fact reviewed and it can increase site maintenance if you change it.

It doesn't hurt, and it helps only a little. But you cannot rely on this for your customer notice without checks and balances.