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#2267548 - 03/11/22 07:40 PM combining e-statements
llcastle333 Offline
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We are looking to combine our customer statements for accounts that have the same owners/mailing addresses. If a customer has consented to e-statements for their checking account but not their savings account, can we still combine these statements or do we need to have them consent to receiving both accounts electronically?

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eBanking / Technology
#2267552 - 03/11/22 08:28 PM Re: combining e-statements llcastle333
rlcarey Online
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rlcarey
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What does your e-sign agreement say as far as what is covered?
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#2267553 - 03/11/22 08:32 PM Re: combining e-statements llcastle333
llcastle333 Offline
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Our e-statement delivery agreement states "for selected accounts".

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#2267565 - 03/11/22 09:17 PM Re: combining e-statements llcastle333
rlcarey Online
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rlcarey
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Well, that does not say much, unless there is a check off box listing the accounts. You need to get your legal counsel to review that agreement. It might not even cover the account at hand, let alone any others.
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#2267567 - 03/11/22 09:29 PM Re: combining e-statements llcastle333
llcastle333 Offline
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Before you can even get the agreement, you have to select what accounts you are requesting to receive e-statements for. I believe that is why the agreement states "for selected accounts". It is also why I think we need the customer to provide consent to receive all accounts combined electronically if they have only chosen one.

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#2267578 - 03/13/22 02:02 AM Re: combining e-statements llcastle333
Richard Insley Online
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Richard Insley
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Toano, VA
It sounds like your e-delivery consent system ties your hands until you get specific authorization from your customer. Remember, also, that the ESIGN demonstrable consent only affects the method of delivery (electrons vs. trees). Permission to bundle account statements is a service agreement--a contract subject to your state law. It can all be rolled together, but work with legal counsel to be sure the service agreement part of it is sufficiently detailed to hold up in court.
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#2267581 - 03/13/22 12:35 PM Re: combining e-statements llcastle333
rlcarey Online
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rlcarey
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Galveston, TX
As Richard says - it only takes one mistake. I remember the nightmares when this became a popular choice and banks thought they were doing customers a favor, until they tied accounts together, for example, that were normally only shared with a spouse and those that were not. That can happen even if there the same owners and addresses. Most banks learned their lesson back in the 90's and will only do that under written or other direct request by a customer.
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#2267582 - 03/13/22 08:11 PM Re: combining e-statements rlcarey
Richard Insley Online
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Richard Insley
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Toano, VA
Originally Posted by rlcarey
banks thought they were doing customers a favor...only shared with a spouse...Most banks learned their lesson back in the 90's and will only do that under written or other direct request by a customer.
Right. All it takes is a case where you have Mr., Mrs., Mr. & Mrs., and Mr. (or Mrs.) with a little something extramarital happening on the side. As soon as bundled statements arrive and the "on the side" account is discovered, the stuff hits the fan.
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