Looking for help with a new process started by the Bank requiring an email address prior to accepting a loan payment via phone. The reason is to send confirmation of payment but also to confirm authorization to make the payment via phone. I'm not comfortable with this new requirement and looking to see if anyone has any input or regulatory insight. I'm also concerned about disclosing this to the customers prior to them calling in.
Thanks so much!

Nacha rules TEL payments

You'll note in Nacha rules that the requirements for initiating a telephone payment are that the payment instructions be recorded and retained for two years or the customer be provided written confirmation of their authorization. In order to submit the confirmations electronically, the customer would first have provide demonstrable consent via the ESIGN process. Also, ESIGN requires that you provide authorization via paper if the customer so desires.

It sounds like your process may require a closer look to make sure it complies with Nacha and ESIGN requirements.

Thanks so much Brian!