Section 1030.3(a) requires you to "make the disclosures required by §§ 1030.4 [the account opening disclosures]...in writing, and in a form the consumer may keep." If you have given these disclosures neither in paper form nor in an ESIGN-enabled electronic document, then you have not given the disclosures. There is no way to "unviolate" the timing requirement, but you still owe these customers a written disclosure. The same two delivery methods (paper or electrons) are options, but it sounds like your normal practice has reverted to paper. If so, that's what I would use for this remedial delivery of the account opening disclosures.