We are in the process implementing eStatements for our mortage and consumer loan customers. It has already been done for regular deposit customers. One concern brought up by management has to deal with how customers submit payments on their loans. Questions posed: 1. Can we enforce an eStatement-ePayment standard? (i.e. - if a customer signs up for eStatements, we require that they must make their payment electronically) 2. If this is feasible, will additional disclosures or changes to existing disclosures be required? 3. If this is feasible, would this generate addtional ongoing tasks to maintain compliance?

If anyone has any guidance or suggestions, it would be appreciated.

No, you cannot impose such a requirement. First, Regulation E doesn't permit you to require that a consumer set up a preauthorized EFT for a loan payment. And if you aren't contemplating preauthorized EFTs, you'll still have a hard time refusing a timely check payment under Regulation Z section 1026.10 or 1026.36.

Thank you John.