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Date: April 23, 2003
To: Chief Executive Officers of All National Banks, Department and Division Heads, and All Examining Personnel
Description: Interagency Guidance on Weblinking Activity
The guidance attached to this bulletin continues to apply to federal savings associations.
The attached weblinking guidance effectively updates previous guidance issued by OCC in Bulletin 2001-31, July 3, 2001 and applies to all financial institutions supervised by the OCC, FDIC, OTS, and NCUA. Thus, the same standards will apply to national banks, thrifts, credit unions, and state non-member banks.
The guidance offers risk management tools that would reduce risk to banks from linking arrangements and with third parties, especially reputation and compliance risks. It applies to banks that develop and maintain their own weblinks, as well as banks that use third-party service providers for this function. It suggests that a bank linking to third-party sites generally should tell bank customers that the bank does not provide and is not responsible for products and services offered through third-party sites.
For further guidance on weblinking issues contact Liz Milor, Bank Information Technology Operations (202) 874-4744, or Jeff Gillespie, Office of the Chief Counsel (202) 874-5200.