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#2236922 - 05/19/20 05:11 PM Core Conversion and e-statements
TeamComply Offline
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We recently went through a conversion, and have discovered e-statement notification never happened and availability of statement for the statements cycling on the last day with our previous core, was very limited. To address this, can we send out a notice to all e-statement customers that these "short statement" statements are available upon request? or must we actually provide them (electronically) to all e-statement customers whether they request for it or not? Wonder what the best way is to address this conversion-related problem. And what issues we need to be concerned about from a compliance standpoint.

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eBanking / Technology
#2236924 - 05/19/20 05:23 PM Re: Core Conversion and e-statements [Re: TeamComply]
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
I am not sure what you mean by "e-statement notification never happened", but if these short statements are standalone statements (not repeated in the next statement issued) then you either need to make them available electronically or mail them. It would be a systemic violation of the periodic statement requirements under DD and E.
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#2236928 - 05/19/20 05:31 PM Re: Core Conversion and e-statements [Re: TeamComply]
TeamComply Offline
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Joined: Aug 2016
Posts: 242
The system generated notification to e-statement customers indicating "your statement is now available" never happened.

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#2236930 - 05/19/20 05:43 PM Re: Core Conversion and e-statements [Re: TeamComply]
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Is that notice part of your E-Sign agreement that indicates you will send them a reminder, as that regulatory requirement went away like 10 years ago or so.
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#2236932 - 05/19/20 05:51 PM Re: Core Conversion and e-statements [Re: rlcarey]
TeamComply Offline
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Joined: Aug 2016
Posts: 242
Yes, this is included in our agreement.

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#2237016 - 05/20/20 03:46 PM Re: Core Conversion and e-statements [Re: TeamComply]
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 9,762
Toano, VA
Originally Posted by TeamComply
what issues we need to be concerned about from a compliance standpoint.
Until you "send (a) periodic statement", the 60-day Reg E error resolution window cannot close. That leaves you exposed to the possibility of stale (but valid) EFT error allegations.
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