Thread Options
#2233172 - 03/17/20 10:03 PM EnrollMobile Deposit & Online Banking Disclosures
Jenny Roberts Offline
100 Club
Joined: Feb 2014
Posts: 139
Tennessee
What kind of disclosures or terms & conditions are required for customer to consent to to enrolling in mobile banking? Also to enroll in online banking?

Return to Top
eBanking / Technology
#2233174 - 03/17/20 10:48 PM Re: EnrollMobile Deposit & Online Banking Disclosures Jenny Roberts
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 5,839
Illinois
Online banking would require Reg E disclosures as outlined in 1005.7.

Terms and conditions are legal documents that outline the responsibilities of each party.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2233178 - 03/17/20 11:38 PM Re: EnrollMobile Deposit & Online Banking Disclosures Jenny Roberts
Richard Insley Offline
Power Poster
Richard Insley
Joined: Oct 2000
Posts: 9,890
Toano, VA
Service agreements are contracts, so you should make every effort to develop them under guidance from your legal counsel--even in these uncertain times. All Reg. E disclosures must be "in writing", and that means ESIGN if you want/need to deliver them electronically.
_________________________
...gone fishing.

Return to Top
#2241889 - 09/01/20 07:09 PM Re: EnrollMobile Deposit & Online Banking Disclosures Jenny Roberts
ckme Offline
100 Club
ckme
Joined: Sep 2002
Posts: 238
To clarify, the online banking agreement for an already established account does not trigger e-sign, but enrolling in e-statements would? Would there be any requirements agreement that could possibly cross the line (ie. cut off times, transfer limits, etc)?

Thanks!

Return to Top

Moderator:  Andy_Z