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#1201179 - 06/15/09 03:41 PM E-Sign and Fees
Steve Doty Offline
100 Club
Joined: Mar 2007
Posts: 137
Nebraska
One of the requirements of an E-Sign disclosure is to:

Inform the consumer how the consumer may nonetheless request a paper copy of a
record and whether any fee will be charged for that copy.

Should this be stated as a specific dollar amount in the disclosure? or will "We may charge you a reasonable service for the delivery of paper copies...." be sufficient?

I believe most banks will use the hourly account research fee or the per copied item fee that is already on the account initial dislosure/fee shcedule. Therefore,disclosing as "a reasonable charge" will be ok.

Thanks for your input.

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eBanking / Technology
#1201207 - 06/15/09 04:03 PM Re: E-Sign and Fees Steve Doty
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The E-sign disclosure itself has to indicate whether there will be a fee for a paper copy, but does not have to say what that fee is. In the spirit of transparency, however, I do recommend that you provide the fee amount with other fees disclosed either with new account paperwork or on your website. If it happens to be the same as the fee you're disclosing a per copied item fee, so much the better.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1201217 - 06/15/09 04:11 PM Re: E-Sign and Fees John Burnett
Steve Doty Offline
100 Club
Joined: Mar 2007
Posts: 137
Nebraska
John,

"In the spirit of transparency".. I like that.


Thanks for quick response and reassurance.

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