Online Banking: Is a paper statement required?
Answer by Andy Zavoina and Richard Insley, BOL Guru
Question: We are new to internet banking. We have our customer statements as part of our online product. The statement has a complete copy of our mailed version. We have customers asking us to stop their paper copy. What are the rules and to start this what would need to do.
Following E-Sign requirements, the customer needs to meet certain requirements such as demonstrating the ability to receive these. Review E-Sign, especially Section 101(c). Then look at 205.17 (Reg. E), especially (c), to ensure proper delivery.
This isn't a difficult process but may be more than you want for a single customer.
Make sure when you say the statement is the same, that you are including either the abbreviated Reg. E error disclosure commonly on the back of statement or the annual notice sent as a stuffer, in your disclosures.
You must also comply with Reg. DD and possibly Reg Z (if your deposit statement serves as a periodic disclosure for an overdraft protection credit product.) See Sections 230.6 and 230.10.
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