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#214282 - 07/22/04 06:04 PM Mandatory E-Statement
Suzie Offline
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Suzie
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Any prohibitions on creating an account type that mandates an accountholder receive electronic statement delivery and only electronic delivery?

Second question, where do I find the requirements that deal with e-statement delivery of statements, i.e. undeliverable statements.

Thanks much for your assistance.
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eBanking / Technology
#214283 - 07/22/04 07:47 PM Re: Mandatory E-Statement
Suzie Offline
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Suzie
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I'm going to answer my own question! If I get it wrong hopefully I'll hear from one of you.

Making e-statement delivery mandatory is prohibited. Consumer has right to paper copy. (could use fees to encourage e-delivery though)

205.17 addresses delivery of e-statements.

I should have done some quick research rather than post this question but had so other things pressing thought I would take the easy way out . Now I have started talking to myself on the internet!
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#214284 - 07/22/04 07:52 PM Re: Mandatory E-Statement
Andy_Z Offline
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Thank you for posting the answers. Often there is a question posted. That person is not the first or the last to ask it, I am 99.9% sure of this ALL the time. Then they post and say, "Got the answer, never mind." This does nothing for the person coming after you researching the same question. So thanks.

The fee incentive is the carrot on the stick for e-delivery and cost - pricing should tie into your product offerings.
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#214285 - 07/22/04 07:57 PM Re: Mandatory E-Statement
Jokerman Offline
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Quote:

Making e-statement delivery mandatory is prohibited. Consumer has right to paper copy. (could use fees to encourage e-delivery though)



We have an "e-checking" account that requires the customer to receive an e-statement. They may request conversion to a paper statement, but if they do so, we will change their account to a different type.

No one is saying this is a violation, are you?

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#214286 - 07/22/04 08:04 PM Re: Mandatory E-Statement
Andy_Z Offline
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No, because you have an alternative, which can be priced differently.
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AndyZ CRCM
My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#214287 - 07/22/04 08:20 PM Re: Mandatory E-Statement
Jokerman Offline
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Quote:

No, because you have an alternative, which can be priced differently.



Ok, that's what I thought. However, Suzie's original question was:

Quote:

Any prohibitions on creating an account type that mandates an accountholder receive electronic statement delivery and only electronic delivery?



I got the impression from her follow-up that she was answering in the affirmative.

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#214288 - 07/22/04 08:46 PM Re: Mandatory E-Statement
Richard Insley Offline
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Richard Insley
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Toano, VA
Quote:

I got the impression from her follow-up that she was answering in the affirmative.

She was--and that was not a correct self-answer. You may not force e-delivery on customers and it's good marketing to have a twin product (differing only as to statement delivery method), but no rule requires you to offer ANYTHING as an alternative.
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#214289 - 07/22/04 10:00 PM Re: Mandatory E-Statement
Suzie Offline
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Suzie
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Thank you so much Richard, Andy & Jokerman. Communciation is not my strong suit today, especially when I'm talking to myself.

I was answering in the affirmative ! I can have a deposit product that specifies e-delivery and if an accountholder of that type of account wants a paper statement too, I must provide it; but nothing to stop me from pricing that paper copy to discourage these requests.

(what had been proposed to me, electronic delivery only and under no circumstances will we provide you with a hardcopy -that we can't do)

Again, thanks much for your help.
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#214290 - 07/22/04 10:06 PM Re: Mandatory E-Statement
Jokerman Offline
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Quote:

I can have a deposit product that specifies e-delivery and if an accountholder of that type of account wants a paper statement too, I must provide it; but nothing to stop me from pricing that paper copy to discourage these requests.



Suzie, if one of our e-checking customer notifies us that they want to receive a paper statement, we say ok, that's fine, but you are no longer eligible for the e-checking account - you will be switched to a free checking account.

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