We have a number of customers who signed up for e-checking and their login IDs have not been accessed for a long time. We want to delete these login IDs because we are paying for them. How long do we need to keep them on file in case someone wants to access their e-statement?

What does your agreement with them say? It should address non-use. You have to convert them to paper now. Do you have a valid snail mail address, are the accounts active, will fees change as a result that will require disclosure and pre-notification?

It states, "If your account(s) is closed or restricted for any reason, or if there has not been any Internet Banking or Bill Payment activity for a period of three (3) consecutive months, accessibility will automatically terminate." E-banking customers have been notified that if a paper statement is required, they will be charged a $7 fee. So my feeling is these customers have been notified when their accessability would be terminated and they would be charged a fee for paper statements.