|Subject:||Guidance for Weblinking Relationships|
|Date of Memorandum:||09/19/2002|
|Expiration Date:|| |
|Signed By:||Smith, Roland|
|FCA Contact Person:||Glenn, Thomas|
|List of Attachments:||none|
September 19, 2002
To: The Chief Executive Officer
All Farm Credit System Institutions
From: Roland E. Smith, Director
Office of Examination
Subject: Guidance for Weblinking Relationships
The purpose of this Informational Memorandum is to provide risk management guidance on Farm Credit System (System) institutions’ weblinking relationships with third parties. A weblinking relationship is a direct connection via the Internet between two or more Web sites. A hyperlink provides access between the Web sites through an electronic pathway that may be displayed as highlighted text, graphics, or a button. When the Web sites are more than informational in nature and involve the marketing of products and services, the weblinking relationship is likely to be contractual and may involve compensation.
Customers and visitors to System Web sites may be provided access by a hyperlink to third party Web sites (typically merchant and other service vendors) to obtain a variety of products and services. Although these weblinking relationships may be useful marketing tools for a System institution, they may result in risk.
An institution should review a third party’s products, services, and information displayed on the institution’s Web site, including the third party’s privacy and security policies. This due diligence should help to minimize strategic and reputation risk.
The following three documents can assist in addressing weblinking risks. They provide further explanation and guidance on the risks of weblinking:
· Farm Credit Administration’s January 16, 2001, Informational Memorandum “Outsourcing of Technology-Related Products and Services.”
· Office of the Comptroller of the Currency’s July 3, 2001, Bulletin “Message
to Bankers and Examiners.” http://www.occ.treas.gov/issue.htm.
· National Credit Union Administration’s March 2002 Letter Number 02-FCU-04 “Weblinking Relationships.” http://www.ncua.gov/ref/letters/02-FCU-04.html
If you have any questions about this Informational Memorandum, please call Tom Glenn, Special Examination and Supervision Division, Office of Examination, at (703) 883-4412, or correspond with him on the Internet at e-mail address firstname.lastname@example.org.