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#1445815 - 09/21/10 02:50 PM Re: Online Banking and E-statements [Re: Cale_N_Oats]
John Burnett Offline
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John Burnett
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Cape Cod
I suggest that you place the PDF document on the same server and in the same folder that the consumer is going to have to access in order to pull down his statement (assuming you're using the "pull" method). Then use your email to the customer to provide instruction on how to access the PDF file. Include information on the PDF document that the customer needs to parrot back to you in his consent, to show that he got to the PDF and could open it.
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eBanking / Technology
#1446017 - 09/21/10 06:22 PM Re: Online Banking and E-statements [Re: John Burnett]
Cale_N_Oats Offline
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Cale_N_Oats
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Southern Illinois
Sorry for being so difficult but I just want to make sure i understand what you're suggestion is. You're saying we should email them instructions on accessing the PDF through their Online Banking and within that email also ask them to respond back that they can access the document?
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#1446279 - 09/21/10 11:06 PM Re: Online Banking and E-statements [Re: Cale_N_Oats]
Richard Insley Offline
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Richard Insley
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Toano, VA
I think the point you're missing is that it's insufficient to get the customer to declare "I have Acrobat reader and can use it to open a test document." ESIGN goes further. It requires you to test the customer's proficiency in a way that demonstrates success with all the hardware & software necessary to retrieve, open, and use the electronic documents containing the periodic disclosures (the statement.)
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#1446305 - 09/22/10 12:30 AM Re: Online Banking and E-statements [Re: Cale_N_Oats]
rlcarey Online
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rlcarey
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Galveston, TX
"have them reply that they "consent" that they have the ability to view and would like to receive e-statements."

IMHO - having them say they have the ability to view the documents is not demonstrable consent. They haven't demonstrated anything.
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#1446899 - 09/22/10 07:49 PM Re: Online Banking and E-statements [Re: rlcarey]
Cale_N_Oats Offline
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Cale_N_Oats
Joined: Aug 2008
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Southern Illinois
So let me run this by you guys and see if it works. We have the customer sign up for E-statements through our server so we can track it. Then we send them an email saysing something like "Thanks for signing up for E-statements with Herrin Security Bank. We have provided a test statement for you to access on your online banking account. Let us know if you have any trouble viewing the test statment." So, they have provided us consent through our server and we have given them a way to test their system. Would this suffice?
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#1446978 - 09/22/10 09:11 PM Re: Online Banking and E-statements [Re: Cale_N_Oats]
John Burnett Offline
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John Burnett
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Those two things are essentially correct, except they are in the wrong order. So add one thing. When you provide the access to the test statement, tell him/her to follow the instructions found there. Include in the instructions a link to a form to be used by the customer to confirm the earlier agreement for e-statements. Now you will have documented consent.
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#1446985 - 09/22/10 09:18 PM Re: Online Banking and E-statements [Re: John Burnett]
Ebankman Offline
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We do something similar to that in our environment. We send our estatements via an encrypted/password protected pdf. To get the customer to prove they can open access the pdf we do the following steps.
1 customer signs form stating they have the minimum system requirements and want estatements.
2 we send an email to them with a sample statement attached in PDF format and ask that they reply to our email with the date on that sample statement.
3 if they reply correctly we turn on estatement and begin sending the statements in pdf format to their email address.

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#1447062 - 09/23/10 02:03 AM Re: Online Banking and E-statements [Re: Ebankman]
Richard Insley Offline
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Richard Insley
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Toano, VA
Originally Posted By: Ebankman
We do something similar to that in our environment. We send our estatements via an encrypted/password protected pdf. To get the customer to prove they can open access the pdf we do the following steps.
1 customer signs form stating they have the minimum system requirements and want estatements.
2 we send an email to them with a sample statement attached in PDF format and ask that they reply to our email with the date on that sample statement.
3 if they reply correctly we turn on estatement and begin sending the statements in pdf format to their email address.

This sounds good for a "push" delivery system (and can be adapted for Mose's system.) The only thing I would change is the content of the customer's confirmation email message. In order to dot the I's and cross the T's, the customer's confirmation email to you should be an affirmative request or confirmation of the earlier affirmative request for e-delivery. Rather than asking the customer to use his/her email client to generate an email message, you're in better control if you use a "mailto:" link or some other way that you can control the Subject line ("Please sign me up for e-Statements") and or the Body of the message ("This is to confirm my request for e-statements. In order to demonstrate my ability to access these e-statements, I have opened and read the sample statement. The date on that statement is"......customer completes final part of message.)
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#1453258 - 10/07/10 08:46 PM Re: Online Banking and E-statements [Re: Richard Insley]
Jayhawker Offline
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Jayhawker
Joined: Oct 2004
Posts: 93
We are looking into doing electronic bank statements for certain types of accounts we offer. As for the required disclosures--first off what disclosures are required (Reg E, Reg CC,????) and are the disclosures (i.e. error resolution notice) suppose to be attached to the bank statements? I know Reg E comes into play--what else??? What about this E-sign you have been talking about?

Basically, from scratch, what do we have to do to start offering electronic bank statements?

Thanks

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