We are on the verge of implementing eSign for our branches for maintenance tasks in addition to account opening and lending. I think this will help with some customers who tend to change signers rather frequently, such as with closers on settlement agents' accounts. I'm beginning to consider whether collecting their signatures on Resolutions adds value, or whether an authorization from the principals in the Resolution is sufficient? I am also considering whether we can use a separate authorized signer list with signatures as an appendix, rather than re-creating a signature card every time there is a signer added or deleted. Am I behind the times?
Can the bank accept an electronically signed form from a customer for unauthorized debit card or ATM activity?
Can email notifications be sent for abandoned property? My understanding is that this is subject to what each state may require depending on the address the account holder is located. Some states require a written notice to be mailed. So if we meet E-SIGN requirements would that supersede state requirements? Would CAN-SPAM Act also need to be considered as not being in violation since it talks about "notification of a change in the recipient's standing or status"? I'm thinking this Act is more related for purposes of commercial electronic mail.
We would like to create an easier way for our consumers to sign up for E-Statements. What are the requirements, compliance wise for this? Currently, our customers need to log into their online banking, view a PDF disclosure that generates a "code", and customer then has to type in code and agree to terms and conditions. Compliance wise- can consumers just sign the disclosure/consent in person at lobby?
We currently keep electronic copies and paper copies of every change made on our website. How critical is it to keep these?
Since Reg Q was eliminated, Marketing wants to start offering NOW accounts to business customers. Can we do that?
We need to communicate a change to our Business Mobile Banking customers. Is it permissible to send these customers (approx. 450 relationships) a text message to their cell phones with a link to the product change description without getting their express consent?
If a business or personal account holder does not look at their checking account e-statement, what are the bank's requirements in mailing the statement?
Reg B - appraisals - can we email a copy of the appraisal to the Borrowers as long as it is secured and we get a read receipt for the email? How long after this do we need to wait to close the loan?
If I email the disclosures to the client and they acknowledge receipt, can I order the appraisal on the same day?