Despite the length of the document, if it is clearly spelled out in the account agreement that they will end up with online banking access, then technically I would think you're covered. I say this with the disclaimer that while I am a life long banker I am not a compliance or legal expert.
If we have to judge compliance by whether the client read and understood the disclosure then we're all in trouble.
With that said, you may want to make sure that folks opening new accounts are clear that online banking access is automatically provided and that they have the option of opting out of said access. You could even have them initial that piece of the document with a yes/no checkbox. Of course you'd have to back that up by removing access for those who have opted out.
Those are my thoughts.....
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