Bob- You have to be able to use three verbs successfully in order to make a compelling argument: disclose, declare, and demonstrate.
Disclosing the pre-consent information is very straightforward and easy to do. You either cover all the points in Section 101(c)(1) or you don't.
Getting the customer to declare (pursuant to Section 101(c)(1)(A)) his/her "affirmative consent" to receive e-documents instead of paper is also fairly straightforward.
The tough nut, however, is setting up the steps necessary for the customer to demonstrate successful use of your e-delivery system in a way that satisfies Section 101(c)(1)(C)(ii). Consumer responses (stated or implied) such as "I got your test document, opened it, and everything worked great" amount to a declaration, not a demonstration. There's no evidence of success. If the test document contains something like follow-through instructions or a PIN the consumer must return to you, that is evidence of success, i.e., a demonstration.