Is the customer going inactive on online banking essentially the same as not opening their mail from a compliance perspective? What, if any, are the eSign implications? Do we have to monitor and start sending them paper statements?

How do you determine if someone is inactive for your online banking system? Are you monitoring the last time they logged onto the system?

We can pull reports to determine if they are inactive. We are not currently monitoring for inactive status but we were considering doing that.

Whether or not you must switch to paper depends not on ESIGN, but rather on the wording of the e-delivery agreement you and the customer entered at the time you got consent.