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#1934940 - 06/23/14 09:49 PM add other docs to existing E statement delivery
gadawg1 Offline
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Joined: Sep 2006
Posts: 419
Georgia
Management is inquiring that they would like to "add" other documents to be sent electronically to existing customers who have signed up for e-statements. These other docs could include year end 1099 forms, schedule of fees etc. In our current E statement agreement, it mentions only that the account statements will be delivered. If we wanted to offer other disclosures related to the account to be included in the electronic delivery, I am not sure how to do so. Has anyone done this or can suggestions be offered? Would another e statement agreement with expanded verbiage regarding other docs have to be sent to existing customers or could an announcement indicating these docs will now be sent, be ok to do?

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#1934989 - 06/24/14 01:08 PM Re: add other docs to existing E statement delivery gadawg1
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Two avenues to get this done. First, make sure that the document in question isn't already allowed to be sent electronically without regard to E-SIGN. Some only require that the receiving party agree to e-delivery (without the E-SIGN dance). The real estate mortgage periodic statement required under section 1026.41 of Regulation Z is one of these items that don't require stepping through all the E-SIGN requirements.

But if the document must be in writing unless the E-SIGN dance is done, you will need to initiate the E-SIGN dialog once again. You can broaden its scope by listing more types of documents, disclosures, statements, notices, etc., as long as all of them are going to be delivered in the same fashion (same access method; equipment requirements; software minimums; etc.). In that way, you can add additional e-delivered items with time.

You cannot simply announce you will add items A, B and C to your e-delivery if the only thing the consumer has agreed to accept electronically is his transaction account statement.
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