There are some things to ask and answer to yourself. Does the customer give anything up for this? That is, is this an additional delivery channel or an alternate?
Savings bonds, Travelers Checks, funded from where?
Account to account transfers, same ownership required on the accounts?
If E-sign is in effect, demonstrable consent requirements may not be met if sending them a disclosure means they don't prove they can do something. If UETA applies in your case, life may be much easier if you make it so. But please don't abuse UETA's (lack of) requirements.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell