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#1639435 - 12/15/11 04:17 PM Esign & Online Banking
compliancecrazy Offline
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compliancecrazy
Joined: Jun 2006
Posts: 98
Southeast
Is it a requirement to get e-sign confirmation / permission in order for a customer to sign up for online banking? This pertains to the online banking agree and disclosure given when someone signs up. The customer does click "accept", but unlike the e-statements, there is no confirmation of an email, etc.

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eBanking / Technology
#1639664 - 12/15/11 06:47 PM Re: Esign & Online Banking [Re: compliancecrazy]
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 9,846
Toano, VA
If the sign-up process includes delivery of initial Reg. E and other required regulatory disclosures, then you must use paper (if it can be delivered timely) or ESIGN-enabled e-delivery. You do not have to use the same method for all e-deliveries. If the method used for statements doesn't work well for account opening disclosures, develop another method. HOWEVER, you must go through the ESIGN demonstrable consent steps separately for each delivery system you use.
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#1639692 - 12/15/11 07:18 PM Re: Esign & Online Banking [Re: Richard Insley]
compliancecrazy Offline
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compliancecrazy
Joined: Jun 2006
Posts: 98
Southeast
The disclosure provided is not a regulatory disclosure. It is only our online banking agreement including terms and conditions.

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#1639770 - 12/15/11 08:26 PM Re: Esign & Online Banking [Re: compliancecrazy]
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 9,846
Toano, VA
If the material to be delivered does not contain federal disclosures, you're free to handle it any way you, your attorney & the customer agree. (Your attorney needs to bless the procedure so you're assured the agreement is enforceable.)
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