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Required Website Disclosures

Question: 
Is it a requirement to provide the Funds Availability Policy, HMDA Disclosure, and our Annual Disclosure Statement on our bank's website for customers to read?
Answer: 

Answer by Andy Zavoina: Generally, no. These are signs required at your main office and/or branch locations, and the website is not typically classified as a branch.

That said, why not do it? It is informative to the customer, and they do not change often so it is low maintenance, and it is one more step toward handling your site as a branch.
Reg CC, Section 229.18 generally requires signage where deposits are accepted
Reg C Section 203.5(e) requires a notice at the home office and at branches
Annual Disclosure Section 350.7(b)requires notices at the main office and each branch.

Answer: 

Answer by Richard Insley: I don't disagree with Andy's conclusion, but "dead stuff" is, perhaps, the greatest compliance risk associated with bank web sites.

Someone decides it would be helpful and informative to post copies of required documents on the web site - even though the paper copies are the ones that your procedures require for official purposes. Later, the official verbiage changes but no one remembers the e-copies. Then, your regulator reviews and compares versions and cites you for providing e-info that contradicts the required disclosures.

First published on BankersOnline.com 2/6/06

First published on 02/06/2006

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