Interstitials. Internet speed bumps.

BAM! Whatever you call them, you’ve seen them before, and chances are, your institution is using them.

And unlike the carnival game, it’s actually no fun at all. 

Despite that, you likely never even gave much thought to your website interstitials.

Hence why, just like those abandoned carnival grounds outside town (that’s too much Welcome to Night Vale for me), you can’t just make them disappear. 

Like essentially everything in Night Vale, that’s bad juju. Bad for your customers or members, and bad for your institution. 

Take a look at your own (if you use them) or visit some of your CU companions in the area. Chances are, some of these institutions have wording which could rival Halloween Horror Nights! (Ok, I kid…mostly…what’s THAT?!)

If you use them, the worst message you want to convey to a member is: “maybe you’re better off hitting ‘Cancel’”. 

Some credit unions take a much softer tone and acknowledge the link goes to a trusted partner site or similar. Best practices include making the “Sure!” or “Let’s Go!” links prominent buttons by size and/or color.

Now they’re not so scary! But the question remains: Why have these interstitials at all?

Marketers know how fickle and impatient their web users are. In fact, they have less than 5 seconds to capture a user’s attraction. Any obstacles at all can easily cause the page to be abandoned. 

Given this knowledge, why do these interstitials exist? It all stems from a guidance issued by the OCC (and reprinted by NCUA) in 2003.

What Did Your Website Look Like in 2003?

Ah, we had just “survived” Y2K. The internet was starting to take on the enormous value it is today. (Sidenote: My company launched its first website in 1996!) However, these were still early days in website development.

You can actually view every version of your site through its history in the Wayback Machine.

Data security was important, yet we didn’t hear about massive hacks on a daily basis, and cyber theft was a new thing. The average person paid little attention to security online. 

MySpace was just starting, bringing with it “glitter kittens” and every imaginable animated gif.

Businesses featured internet “billboards” and added “helpful” content to their sites like weather widgets, visit counters, and more to add fun & interest.

It was the early days of online merchants. 

Consider this era of website a glorified listing, rather than the primary presence it represents now. Information on the company as well as 3rd party partners was common.

A user could visit a company site, learn about a 3rd party service, and click straight through to it. 

The concerns came when sites used browser frames to give the appearance that users were still on the original website.

Legal folks at the regulatory agencies were concerned that consumers, especially those making transactions, may not be aware they were doing business with a separate company. 

A fair assessment for the time, so, on April 23rd, 2003 this guidance was issued: 


Reading through the document, it becomes clear how outdated the information actually is.  This was before anyone considered user experience, or had any statistics on internet marketing.

One item that is critical: the document is only GUIDANCE, not a regulation.

 That said, in 2013, The Financial Brand found that over 80% of all US financial institutions were using these speed bumps while referencing all that “silly lawyer stuff”, a strategy unique to the US. 

Since then, by our own observations, those numbers are on the decline, as institutions have measured the costs against the potential liability.

What are the costs of having a speed bump?

Unfortunately, there aren’t any published studies on exactly how much business institutions may be losing through the use of speed bumps.

Let’s look at what we do know:

A study by Google focused on an interstitial comprised of a pop-up offering a service. The study found when users were expecting a certain page to load and instead were faced with an offer, there was a high percentage of abandonment. (That’s not setting or meeting expectations at all!) 

Based on those results, Google decided to stop displaying pages with any type of interstitial in the mobile environment. 


The basic objective of Google’s search engine is to deliver exactly what the user is looking for. An interstitial creates “friction” in the user experience. 

Is your financial institution over-regulating itself and losing revenue in the process? Here’s an easy method to make members happy and increase income.

We know a lot more today about the importance of user experience online. Here are 3 solid website rules for marketers:

  • You’ve got 5 seconds – The first 5 seconds of any website visit is the golden window that allows your site to explain its value.
  • Make Navigation Easy – Clear, with no surprises nor obstructions.
  • Be Consistent IRL (in real life) – If your business has a presence in the real world (I’m talking branches here), it should be consistent with the website.

That last rule is critical.  Imagine this scenario:

Your institution partnered with a car buying service (Disclosure: My company does offer this). They have an office in your branch. After speaking with an MSR about a loan, you are referred to the auto buying rep. 

However, at the door (which is locked), there is a sign swinging above. It says:

Got your pen ready to sign? Probably not.

This isn’t the strangest example. Imagine going to your branch to apply for a loan and you are greeted with this sign at the front door. 


Credit unions like yours partner with a 3rd party to provide their loan application and serving platform.

Yes. There are institutions which actually place an interstitial after you click “apply for a loan”.  Take a look at this:

 *Sample* Credit Union is not responsible for the product, service, overall website content, security or privacy policies on any external third-party sites. 

What would you think (or do) when you see this message after clicking “Apply”?

It probably doesn’t include, “continue with the application process”.

Industry Self Overregulation

The financial industry puts a lot into stopping over-regulation (for a lot of great reasons).

Then they do it to themselves. 

This outdated guidance took on a life of its own, getting misinterpreted and blown out of proportion for over fifteen years. The result is a detriment to the member experience and, in turn, the institution’s performance.

Cover Your (You Know What)

So internet speed bumps are a negative for your users and your institution. They’re also not necessary. 

So why continue using them with such fervor?

It appears to be a liability concern. 

In conversations with institutions that use them, their compliance staff insist they be present, “because they always have”. Others tell us that their auditors insist upon them.

Perhaps that logic even affects JP Morgan Chase Bank. On their Car Buying Service page, they have a small “disclaimer” at the bottom, stating: 

Chase’s website terms, privacy and security policies don’t apply to the site you’re about to visit. Please review its website terms, privacy and security policies to see how they apply to you. The Chase Car Buying Service is provided by TrueCar.

Chase did not use a disruptive interstitial but did still keep the disclaimer. Of course, the copy is so small most users will not even see it. However, it’s there. Can you say CYA?

Wrapping It Up

Websites in general, and our understanding of what people actually want while browsing, have both come a long way since 2003. The OCC guidance had no intention to impede business or negatively affect the member experience. 

It came at a time when websites, by design, had glaring liability issues, thus mitigating them with disclosures was a popular strategy. Not that it was a good idea back then, either.

These are the facts. 

I get that you will not (and should not) change your practices because of something you read online (wait, there’s irony in that somewhere).

There are institutions large and small not using the interstitial speed bump with partner services.

If you’d like to talk to them to see how they did so without auditor challenge, I’m here to make the connections!

If your examiner insists upon keeping that intrusive warning, soften it to the greatest degree possible!

That might mean more friendly wording or elimination of a click-through interstitial. I know they’re a bank, but the folks at JP Morgan Chase might be worth emulating.

In the end, the decision to have (or not have) interstitials is entirely up to your institution. In my relationships with credit unions, I’d say it’s about a 50/50 split.

Some opt for; some opt against.

What To Do?

I can’t tell you that. However, I can share the information needed to explain your actions. It’s all about providing a seamless member experience, no matter their preferred channel. And you might just do a bit better as a result!

Joe Winn

Joe Winn

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