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#1963579 - 09/22/14 03:52 PM estatements
reknab Offline
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Joined: Oct 2008
Posts: 281
not where I want to be
We currently offer estatemetns but we do not monitor emails that bounce back due to invalid email address. Are we required to do this?

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eBanking / Technology
#1963583 - 09/22/14 03:58 PM Re: estatements reknab
reknab Offline
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Joined: Oct 2008
Posts: 281
not where I want to be
the email that I am referring to that bounce back, is the notification that we send to the customer to let them know their statement is ready for viewing.

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#1963597 - 09/22/14 04:52 PM Re: estatements reknab
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
This was a requirement of Regs. E and DD until about 5 years ago. Just because the regs no longer require it, you're not finished yet.

At the time you & the affected customers switched to e-delivery, you probably used some type of formal agreement. If it was ESIGN-compliant, you told the customer what to do if s/he changed his/her email address. That same agreement may bind you to some course of action--such as switching from e-delivery to paper. Find & read the agreement before deciding whether bounce-back monitoring is necessary.

There's at least one other reason to act. If email is an element of your marketing activity, you don't want a database full of non-working addresses.
_________________________
...gone fishing.

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#1963611 - 09/22/14 05:14 PM Re: estatements reknab
reknab Offline
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Joined: Oct 2008
Posts: 281
not where I want to be
Thank you!

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#1963871 - 09/23/14 02:27 PM Re: estatements reknab
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I'm going to surprise Richard with how rapidly time flies. The revocation of the Federal Reserve's Regulation E interim final rules for the electronic delivery of disclosures were withdrawn in a Federal Register document [72 FR 63452] published on November 9, 2007, with an effective date of December 10 of that year and a "mandatory compliance date" of October 1, 2008. Why the Federal Reserve felt it was necessary to provide a mandatory compliance date for a change that eliminated an interim requirement is beyond my ken.

So it's been almost 7 years.
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BankersOnline.com
Fighting for Compliance since 1976
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#1964102 - 09/23/14 09:18 PM Re: estatements John Burnett
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Originally Posted By: John Burnett
how rapidly time flies---almost 7 years
...then I must be having fun! Retirement is the best job I ever had. smile
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...gone fishing.

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#1964183 - 09/24/14 01:50 PM Re: estatements reknab
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
We are just happy you continue to participate in Bankers' Threads as a "retirement hobby," Richard. I still envy you for the photo of your "office" -- shot of a bare foot resting on the gunwale of a boat, fishing line trailing in the water.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1964227 - 09/24/14 02:44 PM Re: estatements John Burnett
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Originally Posted By: John Burnett
photo of your "office"

It's drafty and has no climate control, but I like it.

My office--fall

My office--summer
_________________________
...gone fishing.

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#1965212 - 09/26/14 09:10 PM Re: estatements reknab
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
My error, Richard. Shoes on this time of year.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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