At least for the time being, putting a link to your error resolution notice in the e-mail notifying the customer that a statement can be picked up may not be enough. The interim rule doesn't address it clearly. However, since the printed statement usually has the disclosure on its backside (and that passes examinations), you could argue that having the link in the e-mail gives the consumer at least the same ability to get to it as provided in the print version. I'm not very comfortable with that, though.
Another, possibly better, approach, would be to include another page in each Web-based statement that provides that sort of disclosure (along with your caveats about prompt review of statements, etc., etc.). Or, if the customer has to log in with a password to get to the statement, perhaps the message could be on the logon page.
Finally, you could think about including the error resolution language in the e-mail notice not as a link, but as part of the message. If so, put it above the link to the statement.
This is an area that the Fed wants comments on, folks. They specifically ask whether the rules for periodic statements should be altered for on-line banking.