[Golfing12]

When we link customers to log ins from our website for their accounts, do we have to include the speed bumps? For example, for online banking, their trust accounts (links to SunGuard) when technically, those might be going out to a third party? Online banking takes them to their bank accounts with us, but technically, it’s not our website – they get linked for example, to Q2, or for Trust, they get linked out to SunGuard.

[rcooper]

If you are linking to a service provider that is acting on your behalf the speedbump isn’t required.

From interagency guidance on weblinking and its risks:
https://www.occ.gov/news-issuances/bulletins/2003/bulletin-2003-15.html
Footnote 3: This guidance applies to links to third parties that offer products, services, or information directly to financial institution customers. It does not apply to operational links from a financial institution’s website to a third-party service provider that is providing services on behalf of the financial institution, e.g., a link to the institution’s Internet banking service provider.

[mcarey]

If we weblink to a site that is taking an application for a student loan and the service provider’s privacy policy is different from ours (we don’t share and they share for marketing, joint marketing and with affiliates about transaction and experiences) will we need to change our privacy policy to reflect this? There is a speedbump on our website that states that they are leaving our site.

[Author]

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