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Question:
When would it be necessary to include a speed bump on a bank web site when moving from the bank web page to other pages such as mortgage or investment affiliates?
Answer:
In April, 2003 there was an interagency guidance statement issued on managing risks associated with weblinking. A copy of this statement is available here.
In the statement, the agencies address the issue of disclaimers and disclosures, including the use of speedbumps. The general principle is that the level of detail of the disclosure and its prominence should be appropriate to the harm that may ensue from customer confusion inherent in a particular link.
Bottom line: you’ll need to do a risk assessment related to the links and make your own determination about whether there would be customer confusion about such things as who they are really dealing with, the information security and privacy rules that would be applicable, and the potential level of harm that may arise for the customer.
First published on BankersOnline.com 3/03/08
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