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#2036480 - 08/31/15 05:24 PM Delete inactive online accounts-paper stmts?
Bec Offline
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Bec
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The Great White North
If we are deleting online accounts due to inactivity. Do we have to send out paper stmts if the only way to retrieve the estatement is through the online account? My thought would be yes. If that is the case or not, would someone point me in the right direction as to how I can back that up through regulation or is it a state statute thing?
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eBanking / Technology
#2036488 - 08/31/15 05:48 PM Re: Delete inactive online accounts-paper stmts? Bec
Richard Insley Offline
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Richard Insley
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Toano, VA
What do you mean by "deleting online accounts?" If you're closing the accounts, then there will no longer be a need to send statements. (???) Do you really mean that these inactive accounts will stay on your books, but you will terminate online services for them? By "accounts", do you mean deposit accounts, only, or are credit cards, HELOCs and other credit products included, too.
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#2036674 - 09/01/15 05:33 PM Re: Delete inactive online accounts-paper stmts? Bec
Bec Offline
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Bec
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I am sorry for not being clear. We deactivate their ability to sign in to internet banking if they do not use it for a period of time. Their accounts are still open and active, just not accessible online until they let us know that they would like to use it again and we reactivate them. That does limit their ability to open their estatements though, so would we need to send them paper statements?
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#2036712 - 09/01/15 07:41 PM Re: Delete inactive online accounts-paper stmts? Bec
Richard Insley Offline
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Richard Insley
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Sorry for my typo, but this sentence should have ended with a question mark "By 'accounts', do you mean deposit accounts, only, or are credit cards, HELOCs and other credit products included, too." We need to establish the type(s) of account(s), because the regulations governing statements (if, when, and how) are not the same for credit products (Reg. Z) and deposit products (Regs. E and DD).

For the sake of discussion, let's say your question relates only to deposit products. The next thing you must determine is whether or not the accounts in question were covered by Reg. E. Since they were enabled with internet banking capabilities, I'll assume that most, if not all, were covered by Reg. E. Accordingly, you turn to Section 1005.9 of Reg. E in order to determine when and how you are required to send a statement. Regardless of your internal policy for declaring accounts (or certain account features) inactive, you must send statements when Reg. E says you must send statements. How you send them is between you and your depositor.

At the time you obtained each e-banking customer's consent to substitute electronic statements for paper statements, you gave him/her a series of disclosures (required by ESIGN) explaining how the e-delivery service will work. Read them. Hopefully, they were worded broadly & spelled out how you will handle termination of e-delivery. If not, now is a good time to have the bank's attorney review and revise your e-delivery service agreements so they DO cover this situation. In particular, if inactivity eventually deactivates your primary statement delivery mechanism, you should spell out the substitute delivery method and any change in service charges that will apply.
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#2036979 - 09/02/15 10:42 PM Re: Delete inactive online accounts-paper stmts? Bec
Bec Offline
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Bec
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The Great White North
Thank you for your feedback and insightful answers.
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#2037521 - 09/08/15 04:13 PM Re: Delete inactive online accounts-paper stmts? Bec
Andy_Z Offline
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In addition to Reg E, do you provide change in terms notices on statements? How would the customer ever get them? If the thought is to get those customers interested in eBanking again by cutting off statements, management needs to find another way. Incent the customer or provide better information, teach the consumer how getting info faster adds to security if there are account problems no one was aware of except the guy who found the debit card with a PIN written on it.
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