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#1171834 - 04/28/09 10:39 PM E delivery of new account disclosures
mbernard Offline
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Joined: Jul 2008
Posts: 109
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???

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#1173565 - 04/30/09 06:36 PM Re: E delivery of new account disclosures mbernard
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,503
On the Net
Some disclosures are exempt from the E-Sign requirements. Many of these are the initial disclosures that you "know" the user can read because they can navigate your site. These are not contract agreements, however. In the cases where a consumer will be obligated in some way, E-Sign and UETA do apply.

I discuss a lot of this in my E-Sign webinar.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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