Skip to content
BOL Conferences
Thread Options
#2237150 - 05/22/20 03:01 PM E-Statements
Newbie06 Offline
Platinum Poster
Joined: Mar 2006
Posts: 731
I understand the whole process of how customers go about receiving e-statements, etc... My question is, if we have a current customer who is already receiving e-statements on their current accounts but then opens another account, can we ask the customer if they would like the new account set up on e-statements or does the customer have to go through the whole process of consenting and opening the documents at home on their computer?

We don't open accounts online.

Does a customer have to consent and acknowledge for each account or once customer consents and acknowledges it's good for any account?

Return to Top
eBanking / Technology
#2237159 - 05/22/20 04:16 PM Re: E-Statements Newbie06
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Totally depends on your agreement that is delivered when they first establish E-Sign capabilities.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2237163 - 05/22/20 04:53 PM Re: E-Statements rlcarey
Newbie06 Offline
Platinum Poster
Joined: Mar 2006
Posts: 731
Ok, then I think we are covered based on the following statement in our E-Sign disclosure:

This Online Banking E-Sign Disclosure and Consent (Disclosure) applies to all
communications for those products, services and accounts offered or accessible through
Online Banking that are not otherwise governed by the terms and conditions of an
electronic disclosure and consent.

You agree that XYZ Bank may provide you with any communications that we
may choose to make available in electronic format, to the extent allowed by law, and that
we may discontinue sending paper communication to you, unless and until you withdraw
your consent as described below. Your consent to receive electronic communications
and transactions includes but is not limited to:
 All legal and regulatory disclosures and communications associated with the
Account(s) or the product or service available through Online Banking for your
Account(s).

Return to Top
#2237166 - 05/22/20 05:07 PM Re: E-Statements Newbie06
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
That about covers it - as they say smile
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2237192 - 05/23/20 12:24 PM Re: E-Statements Newbie06
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
Originally Posted by Compliance1
all communications for those products, services and accounts offered or accessible through
Online Banking
You 'gotta love the word "all!" The only open question is whether the new account is the same set of accountholders as the one when you obtained consent. Let's say you obtained consent from mom for an account that's in her name only. The new account might be in name of mom and dad, mom and child, etc. You're OK as long as legal/regulatory communications only have to be delivered to one of the joint account holders, and mom can be the designated recipient. Should a regulation-mandated notice or disclosure have to be sent to one or all of the other joint account holders, you'll need to be sure you have consent from the others. Remember that each regulation has its own unique set of delivery requirements, so the need to consider the consent status of the other account holders will depend on which regulations apply the the account at hand.
_________________________
...gone fishing.

Return to Top
#2239770 - 07/17/20 04:48 PM Re: E-Statements Newbie06
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 362
Midwest
Dad has online banking and sets all accounts up for estatements. Daughter has a checking account but does not have online banking. Dad is a joint owner on the savings account but is not on her checking account. Are we required to have the primary owner receive a savings statement? Right now, only dad has access to the savings statement. Under Reg E, should the primary receive the savings statement instead of a joint owner?

Return to Top
#2239772 - 07/17/20 05:34 PM Re: E-Statements Newbie06
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
I was not aware that there was a primary accountholder on a joint deposit account. But with that said, if the daughter requests paper statements, you have to give them to her.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2239792 - 07/17/20 08:12 PM Re: E-Statements Newbie06
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Typically a bank sends one statement to an address designated on the account. The same can happen with the e-statement, it can go to one address (or more if your system allows) or be downloadable online. If the daughter has a joint account either of those owners can make some changes. If dad calls for e-statements and then daughter wants paper, she may well end up paying for them if those were the terms of the agreement. Her individual DDA is off limits to dad's wishes on this one. I only mention it since you brought up an individual account.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top

Moderator:  Andy_Z