Topic: Information Technology (IT)
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Our bank wants to implement a chatbot for routine customer interactions and general inquiries. Is there any guidance on what a chatbot can and cannot say? Are there any compliance concerns we should be aware of? For how long do we need to retain the chat scripts?
We are not aware of any federal or state guidance specifying what a chatbot can and cannot say to a customer. The federal banking agencies issued a request for information on financial institutions’ use of artificial intelligence, including chatbots, in March 2021 (with descriptions of some of the related risks), but they have not followed…
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We have added a “device bar” at our main branch with Android and Apple devices that customers can use to access internet banking and sign up for mobile banking. Our wifi network is password-only, which we do not give out to our customers. Through the devices, customers have access to our wifi network, but they can access only our website and a few other specific sites, such as a mortgage calculator website. Do we need to provide any disclosures regarding our wifi network?
No, you are not required to provide specific disclosures, although certain disclosures and policies may be prudent. For example, your bank may wish to require guests to agree to a “wifi acceptable use” policy; we have provided two examples of such policies below. In addition, we note that providing your customers access to a limited…
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Do we need to provide a “click through” disclaimer for links on our website that leave our website and lead to our online mortgage application platform, which is run by a third-party service provider?
No, we do not recommend using a click through disclaimer when linking to a third-party service provider’s website that is providing a service on behalf of the bank. The interagency guidance on web linking recommends using a disclaimer when linking to third-party websites that are “not under direct control of the financial institution.” However, the…