I would consider this question from a future perspective. I agree with Brian and I would recommend using E-SIGN compliant procedures if you have the capacity. Essentially, I would include Reg E in your E-SIGN agreement if you are using E-SIGN already and you are covered. If it isn't in there, make it so. The more you include in your E-SIGN agreement the better because it allows you to react quicker when there is a need and an ability on the consumers part. Without E-SIGN you could send non-federally required disclosures, but if someone then slips up and sends a federally required form without E-SIGN in place, you have a problem.
Also remember that the E-SIGN hoops like demonstrable consent are consumer protections. Commercial customers do not have that requirement.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell