November 19, 2000
WELCOME - We are proud to announce that Diana Rankin has joined Bank Web Site Audits as an Associate. Diana has more than 13 years banking experience. She has worked with loan documentation and consumer compliance. Her experience will benefit us all. Please e-mail Diana at
Diana@yennik.com and welcome her aboard.
FYI - An article from the Chicago FRB about Electronic Signatures in Global and National Commerce Act
CLARIFICATION - Last week we commented about not placing FDIC membership statement and non-deposit disclaimers on the same web page. A reader brought to our attention that it is OK for a web page to contain a link to a non-deposit product web page and have the FDIC membership statement. The problem arises when the web page contains solely non-deposit investment product advertising and the FDIC membership statement. In this case it is not appropriate to include both the non-deposit disclaimer and the FDIC membership statement.
INTERNET SECURITY - Establishing a link between a bank's internal network and the Internet can create a number of additional access points into the internal operating system. Furthermore, because the Internet is global, unauthorized access attempts might be initiated from anywhere in the world. These factors present a heightened risk to systems and data, necessitating strong security measures to control access. Because the security of any network is only as strong as its weakest link, the functionality of all related systems must be protected from attack and unauthorized access. Specific risks include the destruction, altering, or theft of data or funds; compromised data confidentiality; denial of service (system failures); a damaged public image; and resulting legal implications. Perpetrators may include hackers, unscrupulous vendors, former or disgruntled employees, or even agents of espionage. (FDIC December 1997)
Over the next few weeks we will cover the FDIC's paper "Risk Assessment Tools and Practices or Information System Security" dated July 7, 1999.
INTERNET COMPLIANCE - Fair Housing Act
A financial institution that advertises on-line credit products that are subject to the Fair Housing Act must display the Equal Housing Lender logotype and legend or other permissible disclosure of its nondiscrimination policy if required by rules of the institution's regulator .
Home Mortgage Disclosure Act (Regulation C)
The regulations clarify that applications accepted through electronic media with a video component (the financial institution has the ability to see the applicant) must be treated as "in person" applications. Accordingly, information about these applicants' race or national origin and sex must be collected. An institution that accepts applications through electronic media without a video component, for example, the Internet or facsimile, may treat the applications as received by mail.
Have a Happy Thanksgiving