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?
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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?
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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?
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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…