If your e-statement includes change in terms notices, these are required to be in writing under Reg DD. So yes. It doesn't matter if you push or pull. You just have to set your demonstrable consent method as appropriate. When emailing, you'd also want to encrypt the statement. That adds a whole new procedure.
If your e-statement never includes change notices, then technically you are required to deliver the statement, but the law doesn't say "in writing." But that is a fine line you would likely have to argue with examiners about. You'll have to decide if you'd want that.
Last edited by Andy Z; 04/24/09 07:00 PM.
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AndyZ CRCM
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