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#1213479 - 07/07/09 03:55 PM "New Account - Going Green"
VMack Offline
Platinum Poster
Joined: Jun 2001
Posts: 846
Texas
When a customer opens an account in person, is it possible to provide the new account disclosures to the customer by email instead of in paper format? I am told that we want to promote ebanking and "going green". Personal Bankers feel it is contradictory to promote "going green" and then hand the customer a mountain of paper disclosures. According to Reg. DD, in a face to face transaction, we should provide account disclosures to a consumer before an account is opened or a service is provided. Obviously, this would not happen if the disclosures were emailed. Am I missing anything that would allow this? Any other ideas in respect to paper disclosures and "going green"? Thanks for the input.
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VMACK
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“The wise know their limitations; the foolish do not.”
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eBanking / Technology
#1213569 - 07/07/09 05:58 PM Re: "New Account - Going Green" VMack
YoungAndEager Offline
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Joined: Apr 2009
Posts: 135
Indiana
I don't think this would satisfy TISA requirements.
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#1213590 - 07/07/09 06:14 PM Re: "New Account - Going Green" YoungAndEager
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
You would also have to follow the E-sign rules.
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#1213600 - 07/07/09 06:22 PM Re: "New Account - Going Green" Skittles
VMack Offline
Platinum Poster
Joined: Jun 2001
Posts: 846
Texas
LCO83, I agree with you. Yes, I did think about E-sign. I always try and offer an alternative solution to a proposal for change if possible. I just can't think of anything for this one! tired
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VMACK
CRCM

“The wise know their limitations; the foolish do not.”
Benjamin Hoff, The Tao of Pooh

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