Skip to content
BOL Conferences
Thread Options
#2275401 - 09/12/22 04:13 PM Posting Disclosures Online
Mel in WA Online
Diamond Poster
Joined: Mar 2013
Posts: 1,266
Is it acceptable to post disclosures (i.e. EFT Agreement, Funds Availability Disclosure) on your webpage so they can be accessed at anytime by anyone? We currently provide them at account opening.

Return to Top
Deposits and Payments
#2275404 - 09/12/22 04:32 PM Re: Posting Disclosures Online Mel in WA
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
A lot of banks post them on line. If you mean in lieu of actually delivering them at account opening, that answer would be no. If you are not handing them paper, you would need to deliver them via E-Sign, which using E-Sign to deliver them prior to account opening becomes a real challenge.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2275423 - 09/12/22 07:06 PM Re: Posting Disclosures Online Mel in WA
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Unless a disclosure is transaction or customer specific, you can hand them out (electronically, in this case) like any other "take one" item. The important distinction, as Randy advises, is that offering disclosures is not the same as delivering them. Even if you're not required to obtain customer-by-customer receipts, you will have to prove (to your regulator) that your delivery methods are reliable.
_________________________
...gone fishing.

Return to Top
#2275466 - 09/13/22 02:32 PM Re: Posting Disclosures Online Mel in WA
Mel in WA Online
Diamond Poster
Joined: Mar 2013
Posts: 1,266
Thanks guys! I've noticed that several banks have them available online. We will not be changing our "delivery" methods.

One question I thought of overnight....we obtain several of our disclosures from a third party vendor. Is it acceptable from a legal/copyright standpoint, to repost their form on your site?

Return to Top
#2275467 - 09/13/22 02:35 PM Re: Posting Disclosures Online Mel in WA
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,858
Pulling people out of the ditc...
you need to look to your agreement with your vendor regarding that.
_________________________
Providing alternative truths since the invention of time

Return to Top

Moderator:  John Burnett