I don't have it in front of me, but does GLB say you will mail or deliver the notices and is that term defined?
I ask this because you may have customers signed up for Internet banking who are not regular users. Will they receive their disclosures as required? Do you snail mail statements to these folks now or is all correspondence in e-form?
The answers to these may influence your process.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.