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#1434303 - 08/25/10 08:44 PM Revoking Consent on Reg E Opt Ins
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
When sending our confirmation letters on Reg E Opt Ins, we are including the required notice to the customer that they are able to revoke at anytime and how to do this.

We are also adding a line that states how many days it may take for us to process their request. Wondering if other banks have done this and if so what other banks are deeming as "reasonably practicable" for a time frame?

This is how it reads in the Reg:
A consumer may also revoke consent at any time in the manner made available to the consumer for providing consent. A financial institution must implement a consumer's revocation of consent as soon as reasonably practicable.

Any help or opinions you can offer are appreciated!
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I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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Operations Compliance
#1434313 - 08/25/10 08:49 PM Re: Revoking Consent on Reg E Opt Ins 80's Lady
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
In the opinion category: Your bank should be able to implement an opt-out in the same time frame you implement an opt-in. If not, then I suggest you refund any fees you impose in the interim.

Examiners would be gleeful if they thought you were dragging your feet on this...
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#1435793 - 08/27/10 07:59 PM Re: Revoking Consent on Reg E Opt Ins Elwood P. Dowd
Always In Training Offline
Diamond Poster
Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
Our staff has been informed that they MUST do the account maintenance on ANY Reg E opt form (whether consent to optin or revoke consent) the day it is rec'd or have a very good explanation for why it didn't get done. There is no "reasonable" delay for us. It's a simple matter of maintenance. If we can opt them in in a minute, I can opt them out in a minute too.

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