A customer requests to cancel receiving paper statements in the mail. He will be out of town and says he can just check his account on-line through the Bank's Online Banking.

Are there any requirements out there of what additional disclosures/steps that the Bank needs to take to be in compliance with the appropriate regulation(s)?

Please advise and any references I can go to.

Customers can't cancel the requirements of Regulations E, DD, and Z. If the "statements" contain required disclosures, they must be delivered in one way or another.

Our paper statements have the required disclosures but our online banking view does not. It's just there for quick view and mere convenience for the cardholder. Our systems are not currently set up for the customer to receive electronic disclosures. Thank you for your input!

Even our employees have asked if we can stop sending them paper statements (checking account) since they can go on-line and view all the information. The only 'disclosure' that is on the back of our checking account statement is the one to do with "Error Resolution Procedures" for electronic transactions. I'm presuming we're in the same situation as BOGComp.

In addition, if we stopped the paper then we would HAVE to be able to delivery the disclosure electronically or send them out in a special mailing to those customers who don't get paper, right?

Don't forget that many (perhaps most) online banking systems do not provide the on-statement disclosures that are required by Reg. DD, and omit much of the information required by Reg. E.

You simply cannot stop the paper statements unless you can provide all of the required information appearing on the paper statement in an electronic format, and get the customer's demonstrable consent under E-SIGN.

Check w/ your vendor. Our online statements are pdf images of the front and back of the statement. We allow the customer to change their address to Do Not Mail. They do not waive their reg e rights, but acknowledge their statements will not arrive via the postal system. with customers not notifying us of a changed address we include in the disclosures that if it is returned undeliverable or the post office notes they have moved two consecutive times we will not mail and will hold for 90 days. after that, we destroy them and a charge would be incurred for copies of the statements. Our disclosures also state the customer is responsible for notifying us of address changes.

if they move and don't tell us, delivering their mail to an incorrect address potentially places their information in the wrong hands. the post office has stated they will charge us a fee for all mail (whether returned or not) if they continue to return mail to us and they have notified us of the customer's move.

in a roundabout way, reg e forces you to place the customers information at risk. we chose not to take the risk and would rather deal w/ reg e consequences. what are they going to do? tell you to mail the statements? ok, here is the address we have (which is wrong), we'll see it back in the bank in a couple of days.

I have already discussed this approach w/ our OCC examiner and they did not object.