Trade Names on the Internet
Financial institutions may choose to use a name different from their legal name for their e-banking operations. Since these trade names are not the institution's official corporate title, information on the website should clearly identify the institution's legal name and physical location. This is particularly important for websites that solicit deposits since persons may inadvertently exceed deposit insurance limits. The risk management techniques financial institutions should use are based on an "Interagency Statement for Branch Names" issued May 1, 1998.
Financial institutions that use trade names for e-banking operations should:
- Disclose clearly and conspicuously, in signs, advertising, and similar materials that the facility is a division or operating unit of the insured institution;
- Use the legal name of the insured institution for legal documents, certificates of deposit, signature cards, loan agreements, account statements, checks, drafts, and other similar documents; and
- Train staff of the insured institution regarding the possibility of customer confusion with respect to deposit insurance.
Disclosures must be clear, prominent, and easy to understand. Examples of how Internet disclosures may be made conspicuous include using large font or type that is easily viewable when a page is first opened; inserting a dialog page that appears whenever a customer accesses a webpage; or placing a simple graphic near the top of the page or in close proximity to the financial institution's logo. These examples are only some of the possibilities for conspicuous disclosures given the available technology. Front-line employees (e.g., call center staff) should be trained to ensure that customers understand these disclosures and mitigate confusion associated with multiple trade names.
Legal and Compliance Issues