Our e-newsletter program is brand new to us. If we provide a link to an external site that is not co-branded with our bank, are we required to have a speed bump? If so, what is the bare minimum we need to say? The reason I am asking is that we have a speed bump in place on our web site and it is quite lengthy. In this instance, if I were to add the speed bump, it actually has more content in it than our e-newsletter. I do receive e-newsletters from other banks and they do not have speed bumps. Since this area is new to us, I want to have policies in effect as we go forward.
Our Marketing Department wants to allow customers to apply for credit online. We know we have to provide disclosures along with the application. The process as it is now provides the disclosures and customers access them by clicking a button. The application will not be made available until they acknowledge they have received the disclosures; however the system does allow them to click the acknowledgement button without actually accessing the disclosures. The acknowledgement button they click says they have read the disclosures. Is this an adequate process to prove to examiners the disclosures are being provided or do we need to require customers to print out the documents and sign them? How do you prove to examiners customers have received the disclosures in an online environment?
Why were ATMs, debit cards, etc., excluded from the FFIEC Guidance and FAQ document? Aren't they also electronic banking channels?
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What does the FFIEC Guidance, "Authentication in an Internet Banking Environment" mean when it states that the principles should apply to all electronic channels?