Click to return to BOL home page



August 20
Safe Deposit Regulatory Compliance & Legal Issues;
Dave McGuinn

August 26
Keeping Bank Secrets: Things you Can Go to Jail for Telling;
Mary Beth Guard

September 8
Checkup for your RDC Program;
Susan Orr

September 10
Critical Issues on Certificates of Deposit;
Deborah Crawford

September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett



Topic Options
#1379767 - 04/22/10 04:10 PM Reg E Opt-in notice & written confirmation
Southern gal Offline
Platinum Poster

Registered: 03/27/08
Posts: 504
Loc: TN
Is there a difference in opt-in notice and written confirmation. We are considering using the Reg E model notice for our opt-in mailing and have the customer return back to us. Will this comply? We are leaving both in opt-in and opt-out sections on the form.

Top
Operations Compliance
#1380001 - 04/22/10 08:07 PM Re: Reg E Opt-in notice & written confirmation [Re: Southern gal]
Reads Regs Offline
Diamond Poster

Registered: 11/15/04
Posts: 2009
If you modified the model opt-in notice to include language about the consumer's right to revoke the opt-in at any time and how it can be done, then if you provide consumers with a copy of such a notice that they completed then that will serve as written confirmation.

Comment 7 of the OSC to section 205.17(b) of Reg. E states the following:

7. Written confirmation. A financial institution may comply with the requirement in § 205.17(b)(1)(iv) by providing to the consumer a copy of the consumer’s completed opt-in form or by sending a letter or notice to the consumer acknowledging that the consumer has elected to opt into the institution’s service. The written confirmation notice must include a statement informing the consumer of his or her right to revoke the opt-in at any time. To the extent the institution complies with the written confirmation requirement by providing a copy of the completed opt-in form, the institution may include the statement about revocation on the initial opt-in notice.
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

Top


Moderator:  Andy Z, John Burnett, Ken_Pegasus