Click to return to BOL home page



April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina



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: 1978
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