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#1204561 - 06/19/09 06:03 PM eStatement enrollment for the business account
Beth175 Offline
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Joined: Feb 2009
Posts: 153
I understand the ESIGN rules -specifically 101c applies to consumers and not businesses. If we want to offer estatements to our business customers do we still need demonstrable consent? Are we fine having them sign an enrollment form listing which accounts they want to receive the estatements on?
Our software vendor does not currently have the ability for us to include the estatement enrollment online as it does for our consumer accounts.

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eBanking / Technology
#1204595 - 06/19/09 06:41 PM Re: eStatement enrollment for the business account Beth175
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
Enforcing the demonstrable consent requirement isn't necessary for non-consumer accounts. But you do need consent, nonetheless, and a recommend it be either written (paper) or verifiable and attributable electronic permission.

In your business enrollment, include a reference to each of the types of items you can provide electronically, including any notices of dishonor on deposited items, etc.

One other thought: I think it's a good idea to emphasize in the enrollment "dialog" with your business customer the importance of ensuring that estatements be picked up and examined promptly, and that they be picked up by someone who doesn't write checks on the account, if possible. If possible, demonstrate how easy it is for the business to check its account activity daily for questionable transactions.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1204655 - 06/19/09 07:14 PM Re: eStatement enrollment for the business account John Burnett
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,049
Toano, VA
If your state has a UETA, study it and research any litigation. Very likely, you will find it much superior to ESIGN for electronic interaction with commercial customers.
...gone fishing.

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