We switched to E-Statements this month and our provider is saying that the back page of information cannot be available online.

The back of the paper statement covers the member's rights and responsibilites under the Fair Credit Billing Act and a balancing sheet for the account.

Is this required to be disclosed to the member with their monthly statement? Thanks!

If you do not then you must send them the 'annual' notice - at least for FDIC banks.

Did you switch everything to E-Statements?

The members have an option for paper or e-statements. The Fair Credit Billing Act is covered in our membership handbook. The question was just raised if we have to provide it to member's monthly since it is on the back of the statement itself.

I guess my question boils down too.. What disclosures need to be provided with the periodic statement?

I know Reg E requires either periodic or annuall but is there anything for lending/ debit card purchases etc?

With the exception of the Reg. E error resolution notice, typically displayed on the back of deposit account statements, the statement has to have all the same information you put on a print statement.

The Reg E error resolution notice can be the short form if it is on the statement (a separate page is OK). But if it is separate (in the email announcing the statement availability, for example, you will have to use the long form. You can only do e-delivery of the error resolution notice if your ESIGN process included that type of notice. Otherwise, you're stuck mailing a hard copy once a year.

This discussion mentions Fair Credit Billing (implemented within Reg. Z) as well as Reg E. Is this an open-end credit statement, a deposit statement, or both? The regs are similar, but a one-size solution does not fit both.

This is a deposit statement. It is the regular periodic statement for savings/checking and loan accounts. It listed the transactions that occured and the beginning and endign balance. It is a monthly financial statement. Currently the back has a section about "Your Billing Rights" and Errors and questions about electrontic transfers.

Thanks for all your help.

Not to beat a dead horse......but....I am looking for clarification from a Reg. E "Alternative method for providing the annual Error-Resolution notice."

Our e-consent allows for the delivery of account related disclosures, which includes the error-resolution notice. It also allows for email communicaton.

Our means of delivering e-statments will be - one click to receive statements AND another click to see the Error-Resolution notice.

Does this comply with the Reg. E delivery of "on or with" periodic statement rule?

Lori

I think you could make a pretty strong argument that it is "with" the statement, particularly if the click is from the statement.

To avoid any and all controversy about whether it's on or with the statement, you could skip that requirement altogether and us the long form for your monthly error resolution notice. There is no "on or with" requirement for using it.

Unfortunetly, the click is not from the statement. It is a click that sits next to the statement click. I was thinking this concept would have been cleared up with the recent changes.

I think we will send the long form reg. e notice in text form via customer email.

Also, am I correct in assuming that since our e-consent allows for all deposit related communication, we can send our Privacy Policy as well? Do you think we could just link them to our Internet site to obtain the Privacy notice?

Actually I think you'll find your answers set out in section 216.9(c) of Regulation P.