1. Website Disclosures: Minimizing Risk in an Online Market

Website Disclosures: Minimizing Risk in an Online Market

Event ID: 2150550
Date: Recorded on 8/6/2019
Duration: Scheduled for 90 minutes including question and answer period.
Presenter: Daniel A. Cotter, Attorney and Counselor, Howard & Howard Attorneys
Credits: Live webinar approved for 1.5 NASBA credit hours (Management Services)

Website Disclosures: Minimizing Risk in an Online Market

In the Internet of Everything World, most financial institutions have web presence to market their organizations and to connect with the billions of potential customers who are using the internet globally. At the same time, many financial institutions have not reviewed or updated their website disclosures from when they first began to have an internet presence. Making sure the language meets the requirements to avoid myriad legal issues is crucial. Financial institutions must understand how to draft appropriate website disclosures that cover various essential elements, such as privacy rights and GDPR, and make sure that the disclosures match how the financial institution is handling personally identifiable information and security of consumer information. The Federal Trade Commission (“FTC”) _ has increasingly penalized online participants for failing to match practices with disclosures and consents.

Please join Daniel A. Cotter as he provides an overview and the elements of an effective website disclosure, including walking through a sample website disclosure. The session will provide an understanding of the importance of an effective web disclosures program and understanding the ways organizations can comply with the myriad requirements.


  • How to select employees to participate in the self-assessment process
  • Methods to identify hidden risks related to the institution’s products, services and activities
  • How to analyze hidden risks and identify current controls, if any, that are in place to protect the institution from losses and regulatory scrutiny
  • How to assess whether the current controls that were identified are effective
  • Methods for documenting control weaknesses and recommending control improvements
  • The process for assigning responsibilities for control improvements and monitoring results
  • How to develop a periodic advisory report for senior management and the Board that summarizes the progress made towards identifying hidden risks and preventing surprises

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