Our institution is planning to offer a full blown Internet banking site (acct 2 acct transfers, EFTs, bill pay, statement imaging- not sure yet if push or pull, etc.). I know the E-Sign Act says that there s/b general disclosures, hard/soft ware disclosures, agree to recieve e-disclosures, the consumer CAN access the disclosures, and we will re-disclose as the tech requirements change.
My questions are:
1. Where on our website do these need to be available?
2. When do they need to be available? Meaning when during the process of our customer's on-line experience should they be met with these disclosures?
3. At the end of the disclosures listed above, we need options for "I agree" and "I disagree." The selection of one of those options is the electronic signature. Is my statement correct?
4. Any other disclosures required
5. If a customer wishes to change the electronic delivery options, snail mail address, email address, etc. can these processes be explained in an FAQ? Or do these processes need to be in the initial disclosure?
Thanks for your help,
jp