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#1640077 - 12/16/11 04:47 PM eStatement question
Paris Offline
100 Club
Joined: Dec 2005
Posts: 173
Honolulu HI
I was just made aware that once a customer signs up for online banking, they are automatically put on eStatements. If they want paper statements, they are denied online banking. Is this allowed based on what regs state?

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eBanking / Technology
#1640170 - 12/16/11 06:45 PM Re: eStatement question Paris
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
E-delivery of statements (and the numerous federal disclosures they contain) can be a requirement for a new account. There are no regulations that specifically allow or disallow this business practice. Depositors who want paper can choose a different account, so nobody is forced into e-delivery.

In spite of your ability to precondition a particular type of account on e-delivery of statements, you still need to get each account holder's "affirmative consent" to e-delivery of statements (because they contain Reg. E and other federal disclosures that must be delivered "in writing.") To be legal, consent can only be obtained in the manner set forth in Section 101(c)(1) of ESIGN.
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