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#2233172 - 03/17/20 10:03 PM EnrollMobile Deposit & Online Banking Disclosures
Jenny Roberts Offline
100 Club
Joined: Feb 2014
Posts: 182
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?

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eBanking / Technology
#2233174 - 03/17/20 10:48 PM Re: EnrollMobile Deposit & Online Banking Disclosures Jenny Roberts
BrianC Online
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,694
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.
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#2233178 - 03/17/20 11:38 PM Re: EnrollMobile Deposit & Online Banking Disclosures Jenny Roberts
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
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.
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#2241889 - 09/01/20 07:09 PM Re: EnrollMobile Deposit & Online Banking Disclosures Jenny Roberts
ckme Offline
Gold Star
ckme
Joined: Sep 2002
Posts: 255
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!

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