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#1091483 - 12/03/08 11:27 PM Switch of e-statement format
Ngoc Offline
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Joined: Aug 2007
Posts: 80
Our core service provider recently switched the method of providing e-statements from HTML format to PDF format. We sent out a notice of the change to the customer, but after reviewing the E-Sign Act, it sounds like the customer must consent electronically again and demostrate that they can access and view their statement in the new PDF format. Is this correct or is it enough that we sent them the notice of software change?

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eBanking / Technology
#1091557 - 12/04/08 02:59 AM Re: Switch of e-statement format Ngoc
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
No, you need them to again demonstrate their ability to view the document with the new format.
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#1091948 - 12/04/08 07:01 PM Re: Switch of e-statement format Ngoc
Richard Insley Offline
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Richard Insley
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Toano, VA
Every statement sent in PDF format should be resent in HTML format--otherwise, you have not sent the required Reg. E and Reg. DD disclosures. In addition, you should extend the Reg. E error resolution time period for these resent statements. Also, you should continue the HTML format indefinitely until you are able to get every customer to agree to switch to PDF (good luck on that one.)
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#1093052 - 12/05/08 11:40 PM Re: Switch of e-statement format Richard Insley
Andy_Z Offline
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Andy_Z
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Many people have issues installing software. And while you and I and everyone reading this are likely familiar with PDFs, I know some senior citizen users who don't want change in their routine. Those are the potential problems when you ask them to install and use a new program. That is why going through the demonstrable consent is necessary. This would be a substantive change.

I would also go back as ask how this change was made without adequate research. It shouldn't have happened it it was already done.
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