Is it a requirement to have a signed acknowledgement from the customer documenting receipt of the initial EFT/Reg E Disclosure?

We currently require our customers to sign for the disclosures they receive (via the signature card) before ordering debit/ATM cards. Would it be okay to just order the cards without receiving the signed acknowledgement?

Can we assume that if the customer uses the card, they automatically consent and agree to the terms of use, including the liability and reporting provisions of Reg E?

"Is it a requirement to have a signed acknowledgement from the customer documenting receipt of the initial EFT/Reg E Disclosure?"

There is no signature requirements for Reg. E disclosures.

"Would it be okay to just order the cards without receiving the signed acknowledgement?"

Yes, as long as a disclosure has been provided to the consumer within close proximity to the card being delivered and the disclosure addresses all of the required disclosures for use of the card. If it is an existing customer, a new disclosure should most likely be delivered with the card.

"Can we assume that if the customer uses the card, they automatically consent and agree to the terms of use, including the liability and reporting provisions of Reg E?"

This is a contractual issue that should be addressed with your attorney.