Skip to content
BOL Conferences
Thread Options
#2250403 - 03/11/21 04:49 PM Account Disclosures and online account opening
ns Offline
100 Club
Joined: Aug 2016
Posts: 120
How/when do other Bank's that utilize online account opening provide account disclosures BEFORE the account is opened? For example, the Funds Availability Disclosure, EFT Disclosure, Truth In Savings Disclosure. Interested what other Bank's do to meet the regulatory requirements.

Thanks!

Return to Top
Deposits and Payments
#2250404 - 03/11/21 04:52 PM Re: Account Disclosures and online account opening ns
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Ours are part of the process before the customer completes and submits their application. We require our customers to open each one and electronically acknowledge before completing their app.

Return to Top
#2250414 - 03/11/21 06:05 PM Re: Account Disclosures and online account opening ns
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Welcome to ESIGN! Any required federal disclosure that must be provided "in writing" must reach the consumer in a timely manner in one of two forms:
1. paper, or
2. ESIGN-enabled electronic documents

Since the whole idea of online account opening is to avoid paper (and the delay caused when the paper must be mailed), then (if not already accomplished) you will need to insert the ESIGN "informed demonstrable consent" process into the stream of clicks leading to a newly opened account.
_________________________
...gone fishing.

Return to Top
#2250682 - 03/16/21 07:02 PM Re: Account Disclosures and online account opening P*Q
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Originally Posted by P*Q
Ours are part of the process before the customer completes and submits their application. We require our customers to open each one and electronically acknowledge before completing their app.
Pam, are you doing the "E-SIGN dance" before delivering those disclosures electronically? Are you ready for some warmer weather?
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2250899 - 03/19/21 04:23 PM Re: Account Disclosures and online account opening ns
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Yes John, we dance before delivering. And you bet I am! This weekend should be super nice!

Return to Top

Moderator:  John Burnett