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Website Compliance Issues

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When reviewing our website, what are the main compliance issues we need to look for?

First, review your website as an advertisement. All the things you'd look for in advertising compliance should be included. This includes Reg Z and Reg DD triggering terms and whether additional required disclosures are included if triggering terms are included on the website.

Next, if you are taking applications or opening accounts online, you'll need to look at how required disclosures are being delivered and are they being delivered timely. The timing requirements for delivery of application and account disclosures don't change just because the channel is online. If only electronic disclosures are being provided you'll need to look at E-SIGN compliance (I wrote a detailed article on this that was published in the Jan/Feb 2007 issue of ABA Bank Compliance Magazine).

Finally, you might want to review your website from a standpoint of compliance with information security and technology regulations and regulatory guidance. Things like the interagency weblinking guidance, identity theft guidance, etc should be included in your website. The FDIC has put together a very nice compilation of technology-related regulations and publications here, that you should find very helpful in this phase of the review.

First published on 5/21/07

First published on 05/21/2007

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