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#2283037 - 04/04/23 11:08 PM Change in Terms - STMT > Website
COMinnesota Offline
Member
Joined: Dec 2021
Posts: 61
We are changing several terms for our deposit products. We will be providing advanced notice to all customers. The issue we're running into is how to provide notice to customers receiving e-statements. Our software only allows us to have one statement backer at a time for all account types. Unfortunately, many of our accounts are on the same statement cycle so we would need to either include the changes for all applicable accounts on one page or figure out another solution. I would rather not include everything on one page when only a small portion would be relevant to each customer. I believe that could easily result in unnecessary confusion.

One possible workaround is including the change in terms on our bank's website and having a statement message sent informing the customer that there has been a change in terms and to click here for details. Would that workaround be compliant with Reg DD?

It should be noted that this would be for customers who have consented to receive e-statements. I still need to verify if our ESIGN agreement allows for this or not, but assuming it does, could we issue the change in terms notice via a one-click link?

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#2283041 - 04/05/23 11:21 AM Re: Change in Terms - STMT > Website COMinnesota
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
Why do you not just mail them?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2283340 - 04/12/23 08:13 PM Re: Change in Terms - STMT > Website COMinnesota
COMinnesota Offline
Member
Joined: Dec 2021
Posts: 61
The only reason for not mailing them would be cost. However, if we can't provide them electronically, we will plan on mailing them.

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#2283341 - 04/12/23 08:29 PM Re: Change in Terms - STMT > Website COMinnesota
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
Well, there are no one-click rules mentioned in 1030.5.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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