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One recent court case held that disclosures on a website were not effective because the hyperlink was colored, but not underlined, bolded in caps or otherwise conspicuous. A video that played took away attention to the link and there was a pre-checked box that was being agreed to. These are the unknown hazards we deal with today. Guidance isn’t from regulators, but from courts.
Do you “publish” compliance violations for the world to see? That can certainly happen if you have a website or use social media, and what bank today doesn’t? If you weren’t sure, “the world” includes your examiners at all state and federal levels, and your bank’s work is always available for review and critique.
Why Attend – Do these questions cause you concern?
- Are you breaking the laws or regs with your website?
- How many times have violations misled consumers?
- Could, what is on your web page be Unfair or Deceptive?
- Are there Fair Lending problems that could impact your CRA rating?
- Might you be violating children’s protection laws by collecting information?
- If you offer loan applications on our site, is there a problem with ARMs?
Yes, even the simplest of web pages can violate the law, and page counters can tell your regulator how many times a violation has been seen. Just because you saw it on a big bank’s site doesn’t mean it is OK for you to do. You must understand the risks and the rules.
Multiple regulatory requirements influence what you can and should have on your web pages and other online advertising for loans, deposits, fair lending, privacy and regulatory guidance. The rules are not “in addition to,” so much as they must be interpreted and applied to this medium. Some guidance items are unique, and we’ll discuss them, too.
What you will learn - join Andy Zavoina, CRCM, for a two-hour review of:
- what should be audited on your website
- how to audit effectively, and how often
- common website violations
- the basics of electronic disclosures on your site
- what triggers E-SIGN and UETA requirements
- what process you should use to implement website changes
Additional benefit - Your program materials will include workpapers to complete a thorough audit of your website. The program includes practical examples of what to look for to avoid violations and manage change. The bank’s compliance officer and auditor should be the first to know if there is a problem on your site, not the last. Effective auditing and maintenance procedures are the key.
Who Should Attend?
- Compliance and auditing professionals
- Marketing personnel
- Operations, lending and any other personnel who help with website content, change requests and maintenance.
Web Audit Checklist
Website Compliance Review
Questions and Answers