Regulation Regarding Receipt of Deposit By Email
by John Burnett, Jim Bedsole, Andy Zavoina, BOL Gurus Guru BIOS
Question: We are looking to implement email notification of receipt of deposit instead of mailing paper back. I have seen comments on e-statements and E-sign and disclosure requirements but don't think any of that applies to receipts. Can you refer me to the regulation that states we are required to provide a receipt and the corresponding rules?
Answer by John Burnett: There are three things that might require you to provide a receipt for a deposit (other than one made at an ATM). The first would be any applicable state law. The second is any contractual provision in your deposit agreements. The third is customer expectations.
If you have no state law issues and no contractual issues, you're dealing strictly with the expectations of your customers. If you wish to continue providing some form of receipt, you can consider doing it via email.
I used "consider" because you have some security issues to think about. If you don't want to invest in some form of encryption, you might ponder how to send receipts that don't include information about the account number or the dollar amount of the deposit. One possibility that comes to mind is to provide customers with serially-numbered deposit slips. You can then send an email that acknowledges receipt of deposit #99999 and no one other than you and the customer will know which account or what dollar amount was referenced.
And you are correct that e-sign won't apply here, assuming no legal or contractual requirement to send the receipt.
Answer by Jim Bedsole: ...unless the state law or contractual provisions John mentioned require a written receipt for deposits. If the law or contract require written receipt, then E-SIGN would apply if you want to substitute e-mail for that written receipt.
Answer by Andy Zavoina: We used to send receipts for deposits received by the mail teller. We simply opted to send them a receipt and for a 60 or 90 day period, included a letter explaining how they could verify the deposit was received and processed via online banking, an ATM or a few ways via telephone. We then said "and as of X date receipts will no longer be mailed." We had no requirements to send the receipt. We provided other and faster options for verification and by virtue if the mailing time period we mitigated the chances of upsetting the customer, especially those who did this regularly.
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