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#1524 - 05/01/01 06:39 PM Customer Account Statements
PABanker Offline
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PABanker
Joined: Dec 2000
Posts: 491
Blue Ball, PA 17506
I am researching if there are any requirements that must be sent on customer account statments for error resolution. I believe the REG E error resolution may be conducted as an annual mailing. Please reply, what your financial institution does on this front. Thanks

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General Discussion
#1525 - 05/01/01 07:25 PM Re: Customer Account Statements
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If the account has an open-end credit feature you will need an annual or monthly billing rights statenment for the credit piece, too.

As for the Reg E 205.11 disclosures, be sure you have adapted them to include the 90 day period for POS and foreign ATM error resolution, if you avail yourself of it. No need to mention the new account 20/90 day periods in the statement disclosures, though.

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#1526 - 05/01/01 07:34 PM Re: Customer Account Statements
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,750
On the Net
An annual mailing means remembering to do it and reaching allthose to whom it applies. Putting the abbreviated version on each statement is just easier and more economical for us.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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AndyZ CRCM
My opinions are not necessarily my employers.
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#1527 - 05/02/01 12:35 PM Re: Customer Account Statements
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Just musing -- If you are reviewing §205.11 requirements with a view toward delivering statements electronically (assuming, of course, you deal with the e-Sign disclosure rules first), you might find it economical to include the §205.11 notice monthly in an e-mail notifying your customer the statement is available for viewing. I think that's acceptable under the "interim final rule" on Reg E.
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John S. Burnett
BankersOnline.com
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