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.
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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