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#1564418 - 06/14/11 02:30 PM "Free" Checking & eStatments
Polo Offline
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Polo
Joined: Feb 2003
Posts: 178
Our bank offers electronic periodic statements (eStatements) to our customers who request it and consent. However, recently management has proposed to charge a fee for paper statements IF the customer elects to have eStatments AND also wants to continue to receive their paper statements.

Would changing a fee to give them paper statement (in these cases) violate our advertising of “Free checking” accounts?

The eStatement delivery agreement states that a fee “could” be charged. However, the fee amount is not disclosed, which is an other issue I would like opinion on.
Thank you

Ps, We do conform to the E-Sign act. That isn’t an issue.

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#1564426 - 06/14/11 02:29 PM Re: "Free" Checking & eStatments Polo
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
I believe that is acceptable because it's completely the customer's choice. However, since you haven't disclosed a fee, I believe a 30 day notice may be required.
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1564461 - 06/14/11 03:16 PM Re: "Free" Checking & eStatments RR Joker
Polo Offline
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Polo
Joined: Feb 2003
Posts: 178
Would a fee need to be disclosed?

Required?
or
Good sense?

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#1564517 - 06/14/11 04:08 PM Re: "Free" Checking & eStatments Polo
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,420
Galveston, TX
If the fee can be assesed to the account - whether voluntarily or otherwise, you need to disclose it up front to avoid both Reg DD and UDAP complications.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1564634 - 06/14/11 05:39 PM Re: "Free" Checking & eStatments rlcarey
Polo Offline
100 Club
Polo
Joined: Feb 2003
Posts: 178
Thank you Randy.
If the fee is voluntary and occurs on an account that is advertised as “Free”, would this affect the “Free” status of the account causing it to no longer be “Free”?
Thank you friend

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#1564754 - 06/14/11 07:25 PM Re: "Free" Checking & eStatments Polo
Bob The Banker Offline
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Bob The Banker
Joined: May 2010
Posts: 958
Does enrolling in eStatements un-enroll them from paper statements automatically? What action is taken to receive both, it seems kind of odd a customer would receive both...

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