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#2237150 - 05/22/20 03:01 PM E-Statements
Compliance1 Offline
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Joined: Mar 2006
Posts: 589
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?

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eBanking / Technology
#2237159 - 05/22/20 04:16 PM Re: E-Statements [Re: Compliance1]
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 73,292
Galveston, TX
Totally depends on your agreement that is delivered when they first establish E-Sign capabilities.
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#2237163 - 05/22/20 04:53 PM Re: E-Statements [Re: rlcarey]
Compliance1 Offline
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Joined: Mar 2006
Posts: 589
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).

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#2237166 - 05/22/20 05:07 PM Re: E-Statements [Re: Compliance1]
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 73,292
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

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#2237192 - 05/23/20 12:24 PM Re: E-Statements [Re: Compliance1]
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 9,762
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.
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...gone fishing.

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