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#876613 - 12/20/07 04:27 PM e-statements
Jerseygirl Offline
Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
For banks that offer this service:
Do you require your electronic banking customers to receive their statements electronically
How do you handle emails returned due to wrong address (do you flip them back to paper statements)
Did you change your disclosures at all
How did you market
Is it required that you send a monthly email to let them know their statement is available
Do you have any souce I can read more about e-statements

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#876647 - 12/20/07 05:05 PM Re: e-statements Jerseygirl
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
We e-mail our customers a notification that their statement is available. They must go to our internet banking site, and can either view or download and print the statement from there.

E-mails returned revert to a US mail delivery.

Disclosures changed to reflect the above.

E-mail notifications depend on the account type - if it's a savings with a quarterly statement, they receive a quarterly notification.

Sorry, I have no other source, other than our service.
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#876922 - 12/20/07 09:30 PM Re: e-statements RBanker
Brad B Offline
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Brad B
Joined: Apr 2002
Posts: 213
KS
We require e-statements for one certain account type. Essentially we're willing to pay a higher interest rate in exchange for not having to print and mail paper statements for that account. It is the customer's choice, however, to opt for that account over others that don't require e-statements. If the customer decides later that they want to receive their statements by paper, we'll convert their account to the lower interest rate account.

To my knowledge, this is the only way you can "require" a customer to receive their statements electronically. The customer has to consent to receiving the statement electronically under the E-Sign Act. It's the customer's election, you can't force it.

The redelivery "rule" under Reg E is gone so you don't have to try to send the statement again. You might want to, though, revert the delivery to paper if you want to be sure the error resolution notice is sent or if state law or something like that would absolutely require you to send a statement to a working address. We will revert to paper delivery.

We have a separate disclosure to enroll for the product.

We sent a paper statement stuffer to introduce e-statements availability.

Read 230.10 for electronic communication under Truth-in-Savings. You can either (1) send the disclosure (statement) to the consumer's e-mail address or (2) make the disclosure available elsewhere and then you have to e-mail the consumer to tell them it is available and keep the disclosure there for 90 days.

Search for electronic statements in these forums and you'll find lots of discussion and answers to read more.
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#877791 - 12/21/07 10:08 PM Re: e-statements Brad B
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Brad -- Reg DD Section 230.10 is gone, too. There is no 90-day access requirement.
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#877803 - 12/21/07 10:18 PM Re: e-statements John Burnett
Brad B Offline
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Brad B
Joined: Apr 2002
Posts: 213
KS
Of course, the day after I posted this I read about 230.10 being removed. I was just signing on to say that.

Honestly, I don't think that repeal changes much whether to send the customer a monthly e-mail or not. You still have to provide account disclosures "clearly and conspicuously, in writing" per 230.3(a). An e-mail to the customer to me is still the way to go in order to send periodic statements, change in terms notices, etc. under Reg DD.
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