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#1145970 - 03/17/09 02:56 AM E-Statements
taknleavofmysenses Offline
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Posts: 183
USA
If we provide electronic periodic statements using the "pull statement" method, do we have to send an e-mail notification to the customer each time?

Thanks.

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eBanking / Technology
#1146025 - 03/17/09 12:54 PM Re: E-Statements taknleavofmysenses
ahou Offline
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ahou
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Posts: 3,094
No, that part of the regulation went away.
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#1147139 - 03/18/09 05:17 PM Re: E-Statements ahou
Mommy1st Offline
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Joined: Nov 2007
Posts: 13
California
One would think that by eliminating the email notification piece it would make the process a lot less handsy when it comes to "bounced back" emails and therefore a lot easier on the backend, but I am curious about the customer impact. For those that are no longer sending the email alert, have their been customer service issues? Any other problems that one should be aware of? Thanks for sharing!

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#1147650 - 03/19/09 02:04 PM Re: E-Statements Mommy1st
diputs
Unregistered

Our bank in a small rural bank that is slowly coming into the “E – age”.
They want to start delivering bank statements to customers via email.
What and where do I start my search for compliance issues that may stem from this activity?
Does the E-Sign Act come into play? What else?

Thank you for any help.

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#1147966 - 03/19/09 06:22 PM Re: E-Statements
Andy_Z Offline
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http://www.bankersonline.com/bankerstore...roducts_id=1735

Yes, E-Sign will come into play as you make required written disclosures via email. There is a lot to it but many vendors should have good suggestions. You then need to pick the right vendor (assuming you outsource for hardware/software) and ensure that what is done is correct.

What regs will impact you will depend on what all you plan to do. Start with E-SIGN and UETA, consider CAN SPAM if you'll be marketing to these customers.
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#1148405 - 03/20/09 10:58 AM Re: E-Statements
Richard Insley Online
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Richard Insley
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Toano, VA
Originally Posted By: diputs
Hey...
It's got the word Compliance in it...
So, it must be your job to do!!!

This is a root problem which will be a roadblock to success as long as you allow your execs and managers to think this way.

Years ago, I realized that our lenders viewed my department as a dumping ground for anything they could paste the "C" word on. After a good deal of research I found that banks with the most successful compliance programs placed full responsibility for maintenance of compliance on the business unit managers who sold regulated products. That model placed the cost of compliance where it belonged (not in a central office cost center), but gave the business managers better control over their "suppliers."

The "compliance department" became an internal consultant--helping line managers understand their obligations and design appropriate systems to achieve and maintain compliance. I scraped the "C" word off our office door and renamed the department "Regulatory Management."

Our model had good success with the large businesses: trust company, branch banking, credit card, mortgage, student loans, and sales finance. Smaller units like private banking required more hand-holding, but whenever we could help them set up their own QC we did.
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#1151400 - 03/25/09 07:45 PM Re: E-Statements Richard Insley
Bud48 Offline
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Joined: May 2005
Posts: 92
On a recent post (03/16-17/09) it was asked if an e-mail notification needs to be sent to the customer each time a statement is available. The answer was "No, that part of the regulation went away." Could I please have the citing for that. We have gotten conflicting answers to this question and need to nail it down so we can begin our program. Thank you.

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#1151824 - 03/26/09 02:27 PM Re: E-Statements Bud48
Richard Insley Online
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Richard Insley
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Toano, VA
You won't find it in so many words, but reading through the FR notice of final rulemaking ( here ) you'll see reference to the email requirements of the 2001 rules, discussion of the lack of merits of email disclosuregrams, and a final rule which contains none of these requirements.
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#1152241 - 03/26/09 07:15 PM Re: E-Statements Richard Insley
Bud48 Offline
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Posts: 92
Thank you, however, I could not pull up the link. It comes back that the PDF file is not available.

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#1152253 - 03/26/09 07:25 PM Re: E-Statements Richard Insley
Andy_Z Offline
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Bud, instead of asking for a cite of something someone says doesn't exist, ask the person saying there is a requirement, for that cite. It is often easier.

Richard, "disclosuregram" is a new word to me, descriptive though.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1152298 - 03/26/09 07:56 PM Re: E-Statements Andy_Z
Bud48 Offline
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Posts: 92
Thanks.

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#1152446 - 03/27/09 02:15 AM Re: E-Statements Andy_Z
Richard Insley Online
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Richard Insley
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Toano, VA
Originally Posted By: Andy Z
"disclosuregram"

I coined the term as a simple way to refer the mandatory email communications the Fed required in its misguided e-Regs in 2001. It's no longer relevant since these requirements were eliminated.
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#1153358 - 03/27/09 10:04 PM Re: E-Statements Richard Insley
John Burnett Offline
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John Burnett
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Cape Cod
If you click on this link
http://www.bankersonline.com/topstory/topstory_0407.html

you will see that the first several articles there cover the five separate final rules that pulled the plug on the 2001 rules. Each story has a link to the PDF and TXT versions of the Federal Register pages. We store copies of those pages on our servers so that we can find them years later.
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