We have decided to migrate to e-statements. I have a couple of questions:
1. The email notification alerting customers that their statement is available: I seen where the FED published rules but those were never finalized - are there written rules that describes what should be included in the email notification and what should not be included, also timeframe of when notification should be sent?
2. Returned / bounced email notifications: I understand that if we have controls in place to ensure that the email address provided was used and our agreement outlines the steps the customer must take in notifying us of an outdated email address we are in compliance with esign. However, what about red-flags - if the notification is returned - what do other banks do? Do you automaticlaly turn back on paper statements? Do you try to contact the customer by phone, do you restrict the account to get the customers attention???
The Fed issued final rules November 9, 2007. In these rules, it dropped the mandatory use of email as a feature of e-delivery systems which generate electronic versions of the disclosure documents required by Regs. B, E, M, Z, and DD. You are correct about ESIGN. It simply requires you to tell your e-delivery customers how to notify you when they change email addresses or any other bit of information necessary for you to make a timely e-delivery. From the dawn of the e-delivery era, bankers have been concerned about the security and pricing implications of customer-caused problems which would disrupt e-delivery.