If we have to provide the consumer with the new account disclosures prior to the account is opened or the service is provided...
how do we get them the new account disclosure in a compliant time period when....
we need to provide the member with the statement of their rights and the hard/software requirements and then they consent and show they can access the info.
Does showing the member the printed copy at the desk and explaining what is in them, and then sending the electronic version suffice as "providing before account is opened".
BUT....then for the future must the member log on from home and do the consent / decline for receivng all future notices in electronic format?
Hope that makes sense. Help please???