I have a couple of questions to post. I hope that someone out there can share their bank's practice for online banking.
First let me give you an overview......We are just beginning to put together our Online Banking package and gather information and as for now, the only thing that the customer is going to be able to do online is make transfers to/from their account and review account activity.
Here are my questions:
1) Reg E states that the customer must consent to electronic delivery of disclosures. We have our disclosures built into the Online Banking Agreement where the customer must accept the terms of the agreement before continuing with online banking enrollment. Does this suffice for consent to electronic delivery of disclosures?
2) Reg E also states that you need customer authentication for preauthorized transfers (such as use of a security code). Also, once you obtain authorization, you must provide a copy of the terms of the authorization to the consumer either electronically or by paper. I just wanted to know how others are handling this on their site.

hi,

i don't know whether i can help you, but i think that one firm is handling with something like that. maybe you can take a look at their site to find some answers.
its a site about it outsourcing finance and ebanking.

here the link: http://www.sinius.de/c.php/en/services/Services_portfolio.rsys
but i can't garantee that it is really helpful. sorry if not!!!

We do both at this time. When a customer opens an account the customer receives a paper version of REG E. In our telephone banking agreement we include a statement that customer received a REG E at account opening. Many times this service is completed at account opeining. If not then we have covered ourselves.

For online banking we give one at the time service is opened and have an agreement online. This action covers us on all fronts. We do state in our agreement the customer by signing the application agrees to accept disclosures in electronic form with online banking. We do not accept online applications from customers who are not CIP certified at this time. We make new customers come to one of offices as we took the conservative approach.

How do you handle Esign?