Online Access Agreements & Hard Copy Retention Requirements
Answers by Richard Insley and Andy Zavoina, BOL Gurus
Question: Currently, our ebanking customers must sign a printed online access agreement for ebanking service that we must keep in their file. If we were to make the ebanking agreement available online for the customer to view and select 'I agree' upon their initial logon to ebanking, would regulators still require us to keep a signed hard copy in the customer's file?
Answer by Richard Insley: BIO AND CONTACT INFO
If this agreement is executed in accordance with ESIGN, then regulators can not require you to use a paper document.
Answer by Andy Zavoina: BIO AND CONTACT INFO
Aside from your direct question, if you are attempting to execute an E-Sign agreement the online "I Submit" is more efficient than a printed and signed copy. What you need to ensure is that you achieved demonstrable consent which is not achieved in traditional written form.
First published on BankersOnline.com date 08/12/02
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